ENVIRONMENTAL 

ASSESSMENT 

Memphis Regional Intermodal Facility 

Rossville, Fayette County, Tennessee 

Submitted Pursuant to the 

National Environmental Policy Act of 1969 

42 U.S.C. 4332(2)(C) 

Lead Agencies: 

U.S. Department of Transportation 

 Federal Railroad Administration 

Tennessee Department of Transportation 

Cooperating Agencies: 

Federal Highway Administration 

U.S. Army Corps of Engineers 

Mississippi Department of Transportation 

SUMMARY 

Memphis Regional Intermodal Facility i 

6/30/2010 

SUMMARY 

The Norfolk Southern Railway Company (NSR) proposes to construct, own, and operate 

a new intermodal facility (IMF) known as the Memphis Regional Intermodal Facility 

(Memphis Regional IMF) to serve the Memphis Metropolitan area. The purpose of the 

proposed project is to increase freight transportation capacity in the Memphis, 

Tennessee region and to meet current and future demands for freight transportation to 

and from the Northeast U.S. As part of the national transportation system, IMFs play a 

key role in meeting the challenges of freight transport now and in the future. An IMF is a 

facility where freight is transferred from one transportation mode to another, in this case, 

between trains and trucks, to speed the delivery of freight over long distances. 

With intermodal transportation, domestic and worldwide freight moves in sealed 

containers or trailers directly from shippers to warehouses, retail stores, plants, and 

other businesses. IMFs are where containers and trailers are transferred between rail 

and highway. Trains, each of which is capable of carrying the equivalent of 280 

truckloads of freight,1 provide the long-haul while trucks provide the local delivery and 

pick-up (short-haul). A ton of freight transported by rail travels an average of 457 miles 

on one gallon of fuel, while a ton of freight transported by a truck requires approximately 

three and a half times as much fuel to travel the same distance.2 In addition to 

providing an efficient freight transportation alternative to long-haul trucks, the proposed 

Memphis Regional IMF would provide supplemental benefits in terms of reducing 

highway congestion and vehicle miles traveled, improving highway safety, and providing 

energy-efficient and environmentally-friendly freight transportation. 

Based on an economic benefits study, the Memphis Regional IMF would contribute to a 

projected cumulative economic impact to the Memphis, Tennessee region of $2.7 billion by 

2020 and a projected 6,186 new or benefited jobs in the same period.3 Additional annual 

benefits attributable to the Memphis Regional IMF are expected to include reduced costs 

for pavement maintenance ($16.1 million); reduced costs for highway delays ($81.4 

million); reduced costs from fuel consumption and emissions ($20.9 million); and 

reduced costs for highway crashes and fatalities ($20.7 million).4 

In February 2010, Tennessee was selected to receive funds to support the development 

of this project from the U.S. Department of Transportation (DOT), Transportation 

Investment Generating Economic Recovery (TIGER) Program as part of the American 

Recovery and Reinvestment Act (ARRA) of 2009. As a result of this Federal funding, 

the proposed Memphis IMF project is subject to the requirements of the National 

Environmental Policy Act of 1969 (NEPA). This document has been prepared to meet 

those NEPA requirements.5 The DOT Federal Railroad Administration (FRA) and 

Tennessee Department of Transportation (TDOT) are the lead agencies for the 

proposed project. The DOT Federal Highway Administration (FHWA), Mississippi 

Department of Transportation, and U.S. Army Corps of Engineers (USACE) are 

Cooperating Agencies. 

 

1 AAR, Freight Rail Works 280 Fact Sheet, 2009, http://www.freightrailworks.org/280.html. 

2 AAR, “Rail Intermodal Keeps America Moving,” November 2009. 

http://www.aar.org/Economy/~/media/AAR/BackgroundPapers/Intermodal%20Nov%202009.ashx. 

3 Proposed Intermodal Facilities, Fayette County, TN, Twelve-Year Impact Analysis: Analysis of Economic, Employment 

and Tax Revenue Impacts 2009-02020, Insight Research Corporation, May 27, 2009. 

4 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 

5 See FRA NEPA requirements at 64 Fed. Reg. 28545 (May 26, 1999); see also FHWA NEPA requirements at 23 C.F.R. 

771 (2009), 65 Fed. Reg. 33960 (May 25, 2000). 
SUMMARY 

Purpose and Need 

The Memphis Regional IMF would be built to improve freight transportation capacity in 

the Memphis, Tennessee region. The additional capacity is required to meet the 

growing freight demand. Anticipated benefits of the project include reducing highway 

and interstate congestion and providing energy efficient alternatives for current and 

future freight transportation.

To meet operational requirements, the main components needed for the IMF are: 

 Tracks connecting the Memphis Regional IMF site to the NSR mainline; 

 Six 4,050 foot long pad tracks to handle train engines and cargo to 

optimize transportation efficiency and maximize fuel savings and 

emissions reductions; 

 Support yard with 34,500 feet of track in parallel strips to allow longer 

trains to be separated until they can be loaded/unloaded; 

 Paved areas for parking approximately 2,200 trailers and containers on 

chassis necessary for daily operations at the IMF; 

 Several small administration, maintenance, and operations buildings 

located on the support yard pad necessary for transportation operations, 

security, and maintenance; and 

 Equipment maintenance pad with spill control and stormwater 

management features and other related facilities. 

Alternatives 

A suitable location is a critical requirement to satisfy the Memphis Regional IMF purpose 

and need. NSR used the following critical evaluation factors to consider a site viable: 

 Sufficient Land. Sufficient land, properly configured, is necessary to develop a 

facility, which can meet intermodal demand and support the IMF operating 

requirements. 

 Proximity to Rail Infrastructure. The project must be located near the NSR 

mainline. 

 Proximity to Highway Infrastructure. The proposed site must be located in 

proximity to adequate highway infrastructure. 

 Location. The proposed IMF must be located near potential customers in an area 

convenient for industrial and commercial economic activities. 

Six alternative locations were evaluated for the Memphis Regional IMF project. Two of 

the alternatives were within Shelby County. The remaining four alternatives were in 

Fayette County and each proposed construction of a new IMF. 

Memphis Regional Intermodal Facility ii 

6/30/2010 
SUMMARY 

All but one of the proposed build alternatives were eliminated from further consideration 

because they failed to meet one or more of the critical evaluation factors or were 

considered to be inferior to Build Alternative 1 due to impacts on traffic, cultural, and/or 

aquatic resources. The NSR prefers Build Alternative 1 and Tennessee Department of 

Transportation (TDOT) and FRA concurred that Build Alternative 1 is the only 

reasonable action alternative, and considered this alternative along with the No-Build 

Alternative (no-action) in this EA. 

Build Alternative 1 consists of constructing and operating a new IMF in southern Fayette 

County, Tennessee, approximately 25 miles east of Memphis. The Memphis Regional 

IMF would be located approximately 1.5 miles south of State Route (SR) 57 and 0.5 

mile west of Knox Road in the City of Rossville. The facility would occupy about 380 

acres on a 650-acre parcel. The facility would include lead tracks from the NSR 

mainline, a loop track, container and trailer transfer and storage yard, SR-57 

overpass and an access road. The overpass would create a grade separation between 

the lead tracks and SR-57. The loop track at the south end of the facility would allow 

trains to reverse direction to return to the mainline. Industrial Road, the access road to 

the IMF, would connect the facility to U.S. Highway (US Hwy) 72. Industrial Road is 

being built by the adjacent property owner (Developer) to not only provide vehicle and 

truck access to the Memphis Regional IMF from US Hwy 72, but facilitate industrial and 

commercial development in the immediate area of the road. While Industrial Road is 

being developed with non-Federal funds, the direct, indirect and cumulative impacts of 

Industrial Road are evaluated as part of this EA. 

As part of the conceptual design process, several adjustments to the IMF were 

considered. The design was modified where possible to avoid, and in all cases 

minimize, impacts to natural resources while balancing engineering restrictions. These 

adjustments to Build Alternative 1 evaluated measures to avoid impacts to the 

environment, to minimize impacts, or to enhance the environmental resources. For 

example, the conceptual layout of the facility was shifted to avoid a wetland and 

enhance the local environment through a commitment to preserve the stream’s 

meanders. 

Environmental Impacts 

The primary potential impacts of the recommended action are outlined in Table S-1 in 

accordance the National Environmental Policy Act, its regulations and other applicable 

law. 

Table S-1: Potential Impacts of Build Alternative 1 

IMPACT CATEGORY POTENTIAL IMPACTS 

Project Features 

Estimated Area 

Property – 650 acres with 440 acres disturbed 

Facility – 380 acres with 233 paved, 76 acres 

tracks, and 71 acres open (green space) 

Estimated Cost $129 million 

Farmland 330 total acres 

Prime and Unique 311 acres 

Memphis Regional Intermodal Facility iii 

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SUMMARY 

Memphis Regional Intermodal Facility iv 

6/30/2010 

Table S-1: Potential Impacts of Build Alternative 1 

IMPACT CATEGORY POTENTIAL IMPACTS 

Transportation 

Improved efficiency in transporting freight. 

Reduced long-haul truck traffic and associated 

congestion and emissions 

Social and Economic 

Residential Relocations and Business 

Displacements No Relocations or Displacements 

Economic 

Approximately 140 new full-time jobs plus 

temporary construction jobs; economic impact of 

$2.7 billion by 2020, and growth of 6,186 new or 

benefited jobs 

Energy 23.8 million gallons of fuel estimated saved on 

annual basis 

Air Quality No Adverse Effects 

Noise No Adverse Effects 

Cultural Resources 

 Architectural/Historic Resources 0 sites 

 Archaeological Sites 0 sites 

Section 4(f) Resources None 

Natural Resources 

Stream 5,352 linear feet 

Wetlands 7.3 acres 

Aquifer/Groundwater No Adverse Effects 

Floodplain Zone A – 1 acre impacted 

Threatened and Endangered 

Species (Federal and State) No Adverse Effects 

Invasive Species No Adverse Effects 

Visual No Adverse Effect 

Hazardous Materials No Adverse Effects 

Areas of Controversy and Unresolved Issues 

There are no major areas of controversy or any substantial unresolved issues related to 

the proposed Memphis Regional IMF project. The public and agencies have provided 

comments on several issues including impacts to air, water, and land resources, and 

impacts on traffic and noise, including cumulative impacts. The EA includes in-depth 

discussion to address these concerns. 

There are three highway projects in the general vicinity of the proposed Memphis 

Regional IMF including: 

 Widening US Hwy 72 in Mississippi, 

 Connecting SR-385 to I-40 in Tennessee and 
SUMMARY 

Memphis Regional Intermodal Facility v 

6/30/2010 

 Construction of I-69 / I-269. 

Industrial Road would connect the facility to US Hwy 72 in Mississippi, which is still twolanes. Mississippi Department of Transportation (MDOT) is programming this portion of 

US Hwy 72 to be widened to four-lanes.6 The stretch of US Hwy 72 in Tennessee, 

which connects to SR-385, is a four-lane highway. TDOT is programming SR-385 to be 

four-lanes from US Hwy 72 north to Interstate 40 (I-40), which would allow for truck 

traffic from I-40 to effectively bypass Germantown and Collierville. These improvements 

being completed on SR-385 would tie into I-69 including the I-269 outer loop. I-69/I-269 

road project would allow for improved truck traffic flow around the Memphis area. 

Other Required Federal and State Actions 

The following Federal and State permits would be required from the US Army Corps of 

Engineers (USACE) and the Tennessee Department of Environment and Conservation 

(TDEC) for implementation of the proposed project: 

 USACE Individual or Nationwide Permit for Impacts to Waters of the U.S. 

(including wetlands and aquatic resources) 

 TDEC Aquatic Resource Alteration Permits (ARAPs) Individual or 

General Permit for Construction and Removal of Minor Road Crossings. 

 TDEC Aquatic Resource Alteration Permits (ARAPs) Individual or 

General Permit for Minor Alterations to Wetlands. 

 TN National Pollutant Discharge Elimination System (NPDES) Individual 

Stormwater Permit for Construction 

 TN NPDES Construction General Permit (if needed). 

SAFETEA-LU Statute of Limitations 

A Federal agency may publish a notice in the Federal Register, pursuant to 23 U.S.C. 

139(I), indicating that one or more Federal agencies have taken final actions on permits, 

licenses or approvals for a transportation project. If such notice is published, claims 

seeking judicial review of those Federal agency actions will be barred unless such 

claims are filed within 180 days after the date of publication of the notice, or within such 

shorter time period as is specified in the Federal laws pursuant to which judicial review 

of the Federal agency action is allowed. If no notice is published, then the periods of 

time that otherwise are provided by the Federal laws governing such claims will apply. 

Conclusion 

NSR proposes to construct and operate the Memphis Regional IMF. The purpose is to

improve freight transportation capacity in the Memphis, Tennessee region to meet the 

growing freight transportation demand. Anticipated benefits of the project include 

economic and employment benefits as well as a reduction of long-haul truck traffic on 

congested highways between the Memphis region and the Northeast U.S. Less longhaul truck traffic should reduce damage to highways from heavy trucks, decrease traffic 

 

6 Mississippi DOT 2010-2013 STIP, US72 from FR302 to Tennessee State Line, NEED ID 4752. 
SUMMARY 

accidents, and improve air quality through the use of energy efficient transportation 

alternatives. 

In accordance with NEPA, the assessment of impacts of Build Alternative 1 and any 

adverse effects, including indirect and cumulative effects, was performed in consultation 

with other Federal and State agencies that have jurisdiction by law or special expertise 

regarding particular resource areas and impacts. Primary impacts relate to construction 

of Build Alternative 1 and those that would remain following avoidance and minimization 

measures are addressed through mitigation, in accordance with applicable Federal and 

State legal provisions. Site design, construction, and facility operation alternatives are 

proposed to lessen environmental effects. Additional environmental enhancement 

measures are proposed to minimize remaining effects as discussed in the EA sections 

3.3 Traffic, 3.8 Noise, 3.12 Natural Resources, 3.14 Visual, and 3.15 Energy. Build 

Alternative 1 is among several alternative sites reviewed and was chosen following 

evaluation of purpose and need and other criteria. 

Memphis Regional Intermodal Facility vi 

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LIST OF ACRONYMS

LIST OF ACRONYMS 

ATRA Air Toxics Risk Assessment 

AAR Association of American Railroads 

AASHTO American Association of State Highway and Transportation Officials

AGS Automated Gate System 

AMEC AMEC Earth & Environmental, Inc. 

amsl Above Mean Sea Level 

APE Area of Potential Effect 

ARAP Aquatic Resource Alteration Permit 

AST Aboveground Storage Tank 

ATA American Trucking Association 

BMP Best Management Practices 

CAA Clean Air Act 

CAAA Clean Air Act Amendments 

CAFE Corporate Average Fuel Economy 

CAFO Concentrated Animal Feeding Operation

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation, and 

Liability Act 

C.F.R. Code of Federal Regulations 

CH High Plasticity Clay 

CL Low Plasticity Clay 

CMAQ Congestion Mitigation and Air Quality 

CN Canadian National Railway 

CO Carbon Monoxide 

CO2 Carbon Dioxide 

COSA Cost of Community Services Analysis 

CWA Clean Water Act 

dBA Decibel (A-Weight) 

DOC (U.S.) Department of Commerce 

DOI (U.S.) Department of Interior 

DOT (U.S.) Department of Transportation 

DPM Diesel Particulate Matter 

EA Environmental Assessment 

Memphis Regional Intermodal Facility vii 

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LIST OF ACRONYMS

EFO Environmental Field Office 

EIS Environmental Impact Statement 

E. Coli Escherichia coli 

EO Executive Order 

EPA (U.S.) Environmental Protection Agency

ESA Endangered Species Act 

ETW Exceptional Tennessee Waters 

FAA Federal Aviation Administration 

FAF Freight Analysis Framework 

FEMA Federal Emergency Management Agency 

FHWA Federal Highway Administration 

FIRM Flood Insurance Rate Map 

FONSI Finding of No Significant Impact 

FPPA Farmland Protection Policy Act 

FRA Federal Railroad Administration 

FRSA Federal Railway Safety Act of 1970 

FTA Federal Transit Administration 

FWS (U.S.) Fish and Wildlife Service 

GDP Gross Domestic Product 

GHG Greenhouse Gas 

GWI Ground Water Institute, University of Memphis 

HAPs Hazardous Air Pollutants 

HCM Highway Capacity Manual 

HOP Highway Occupancy Permit 

HUC Hydrologic Unit Code 

ICC Interstate Commerce Commission 

ICCTA Interstate Commerce Commission Termination Act 

IMF Intermodal Facility 

IRIS Integrated Risk Information System 

ISTEA Intermodal Surface Transportation Efficiency Act of 1991 

LEED Leadership In Energy And Environmental Design 

Leq Energy-Equivalent Sound Level 

Ldn Day-Night Sound Level 

LOS Level Of Service

Memphis Regional Intermodal Facility viii 

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LIST OF ACRONYMS

LWCF Land And Water Conservation Fund 

MCIDA Marshall County Industrial Development Authority 

MDAH Mississippi Department Of Archives And History 

MDES Mississippi Department of Employment Security 

MDEQ Mississippi Department of Environmental Quality 

MDOT Mississippi Department of Transportation 

MDWFP Mississippi Department of Wildlife, Fisheries, and Parks 

mph Miles Per Hour 

MPO Metropolitan Planning Organization 

MRP Major Road Plan 

MS4 Municipal Separate Storm Sewer System 

MSATs Mobile Source Air Toxics 

NAAQS National Ambient Air Quality Standards 

NAC Noise Abatement Criteria 

NAGPRA Native American Graves Protection and Repatriation Act

NCA Noise Control Act 

NEPA National Environmental Policy Act 

NGO Non-Governmental Organizations 

NHPA National Historic Preservation Act 

NO2 Nitrogen Dioxide 

NOx Nitrogen Oxides 

NOAA National Oceanic and Atmospheric Administration 

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service

NRCS Natural Resources Conservation Services 

NRHP National Register of Historic Places

NHTSA National Highway Traffic Safety Administration 

NSR Norfolk Southern Railway 

NWSRS National Wild and Scenic River System

O3 Ozone 

ONRW Outstanding National Resource Waters 

Pb Lead 

PM10 Particulate matter less than or equal to 10 micrometers 

PM2.5 Particulate matter less than or equal to 2.5 micrometers 

Memphis Regional Intermodal Facility ix 

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LIST OF ACRONYMS

PHMSA Pipeline and Hazardous Materials Safety Administration 

PND Pond 

POM Polycyclic Organic Matter 

RCRA Resource Conservation and Recovery Act 

ROW Right-of-way

RPO Regional Planning Organization 

RSPA Research and Special Projects Administration

SAFETEA-LU Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 

Legacy for Users 

SARA Superfund Amendments and Reauthorization Act 

SFHA Special Flood Hazard Area 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

SR State Route 

SPCC Spill Prevention Control and Countermeasure 

STB Surface Transportation Board 

STR Stream

STIP State Transportation Improvement Plan

STP Sewage Treatment Plant

SWPPP Storm Water Pollution Prevention Plan

TACIR Tennessee Advisory Committee on Intergovernmental Relations 

TDEC Tennessee Department of Environment and Conservation 

TDOT Tennessee Department of Transportation

TDOT ED TDOT Environmental Division 

TESA Tennessee Environmental Streamlining Agreement 

THC Tennessee Historical Commission

TIH Toxic Inhalation Hazards 

TIP Transportation Improvement Program 

TMC Turning Movement Counts 

TMDL Total Maximum Daily Load 

TMSP Tennessee Multi-Sector General Permit for the Discharge of Storm 

Water from an Industrial Activity 

TNM Traffic Noise Model 

TRANSCAER Transportation Community Awareness and Emergency Response 

Memphis Regional Intermodal Facility x 

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LIST OF ACRONYMS

TEA-21 Transportation Equity Act for the 21st Century 

TPR Transportation Planning Report

tpy Tons per Year 

TVA Tennessee Valley Authority 

TWRA Tennessee Wildlife Resources Agency

UGB Urban Growth Boundary 

UIC Underground Injection Control 

USACE U.S. Army Corps of Engineers 

U.S.C. U.S. Code 

USDA U.S. Department of Agriculture 

USGS U.S. Geological Survey 

US Hwy U.S. Highway 

UST Underground Storage Tank

VMT Vehicle-Miles Traveled 

vpd Vehicles per Day 

VOC Volatile Organic Compound 

WIN Workforce Investment Network 

WTL Wetland 

WWC Wet Weather Conveyance

WWTF Wastewater Treatment Facility 

Memphis Regional Intermodal Facility xi 

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Memphis Regional Intermodal Facility xii 

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Memphis Regional Intermodal Facility xiii 

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ENVIRONMENTAL COMMITMENTS 

The project will be developed in accordance with all applicable laws and the Tennessee 

Department of Transportation’s (TDOT’s) Standard Specifications for Road and Bridge 

Construction and Norfolk Southern Railway Company (NSR) Standard Specifications for 

Roadbed, Track and Structures. TDOT specifications address sediment and erosion 

control and siltation; channelization; floodplains; construction impacts; utility relocation; 

and traffic maintenance and detours. Best Management Practices (BMP) will be 

stringently implemented throughout the construction period. 

If the project is approved, NSR will utilize the following measures to avoid, minimize, 

and/or mitigate impacts to the human and natural environment associated with 

construction and implementation of Build Alternative 1. 

 Wetlands – NSR will avoid wetlands where possible and minimize impacts to the 

extent practicable. However, wetlands within the footprint of the facility (7.31 

acres) may be impacted by the proposed project. Unavoidable impacts to 

wetlands will be mitigated as required by permitting agencies. As on-site 

mitigation is impractical, NSR proposes to purchase wetland mitigation credits 

from the Wolf River Mitigation Bank at a 2:1 ratio.

 Streams – NSR will avoid streams where possible and minimize impacts to 

streams to the extent practicable. Streams within the footprint of the facility may 

be impacted by the proposed project. Based on the current design, 5,352 linear 

feet of stream channel may be impacted. Potential water quality impacts will be 

minimized through the implementation of BMP during both construction and 

operation of the facility. The unavoidable loss of stream channel will be offset 

through compensatory mitigation. NSR proposes to mitigate through 

Tennessee’s stream mitigation in-lieu-fee program, which will ensure that 

appropriate stream mitigation is accomplished within the same watershed. 

 Floodplain – NSR will incorporated the construction and maintenance practices 

outlined in the local floodplain practices, to the extent practicable, and do not 

anticipate floodplain impacts. For this project, NSR has adopted all construction 

and maintenance practices in Fayette County’s floodplain management 

regulations. 

 Stormwater - NSR will construct and implement a stormwater detention system 

that will provide adequate storage and treatment of stormwater runoff. Detention 

basins will be of adequate size and discharge pipes will include control valves to 

serve as spill prevention and protection devices in the unlikely event that a spill 

leaves the concrete pad area. The detention basins will be lined with at least a 

12-inch thick layer compacted clayey soil to reduce infiltration. Appropriate BMP 

will be followed to minimize erosion, turbidity, and/or other potential impacts to 

streams. Degradation of waters will be avoided through the implementation of 

BMP and a site-specific Storm Water Pollution Prevention Plan (SWPPP). 

 Permits – NSR will comply with all permitting requirements with respect to 

impacts to wetlands and streams, and as required by Sections 401, 402, and 404 

of the Clean Water Act (CWA) as well as Tennessee’s Aquatic Resource 

Alteration Permit (ARAP) program. Applicable permits include: 
 

Memphis Regional Intermodal Facility xiv 

6/30/2010 

o USACE Individual or Nationwide Permit for Impacts to Waters of the 

U.S. (including wetlands and aquatic resources). 

o TDEC Aquatic Resource Alteration Permits (ARAPs) Individual or 

General Permit for Construction and Removal of Minor Road 

Crossings. 

o TDEC Aquatic Resource Alteration Permits (ARAPs) Individual or 

General Permit for Minor Alterations to Wetlands. 

o TN National Pollutant Discharge Elimination System (NPDES) 

Individual Stormwater Permit for Construction. 

o TN NPDES Construction General Permit (if needed). 

 Air - To reduce potential air impacts of the facility to near-by residents, NSR will 

use ultra low-sulfur transportation grade diesel fuel (0.0015 percent sulfur) for 

NSR container and trailer handling equipment. NSR will use Tier 4 technology7

for the overhead lift cranes. 

 Noise and Visual – To reduce potential noise and visual impacts of the facility to 

near-by residents, NSR will to construct earthen berms along portions of the 

eastern and western sides of the facility as well as along portions of the western 

side of the lead track. Along the western edge of the proposed lead adjacent to 

the residences along Neville Road, NSR will construct a landscape berm where 

the top of the berm will be approximately 15-foot higher than the adjacent top of 

rail. Additional visual impacts will be controlled by using non-standard 70-foot tall 

light poles in areas requiring illumination with downward directed fixtures to 

reduce off-site impacts. To reduce potential construction impacts, NSR will 

implement standard noise and light controls and related BMP. 

 Archaeological – To reduce impacts if an unidentified archaeological site is 

found during construction, NSR will cease all construction activities in the 

immediate area where archaeological material is discovered. NSR will not restart 

construction activities in this area until appropriate clearances have been 

obtained. The Tennessee Division of Archaeology and any Native American 

tribes with interests in the area will be immediately contacted so that 

representatives may have the opportunity to examine and evaluate the 

archaeological material. 

 Operational Measures – To reduce operational impacts, equipment will be 

maintained and serviced only in the designated maintenance pad area and 

appropriate treatment systems and controls will be in-place and operational in 

accordance with applicable permit requirements. The facility will also be secured 

by fencing and close circuit monitoring to prevent vandalism and unauthorized 

site access. Facility staff will be properly trained on appropriate emergency 

response actions and protocols in the unlikely event of a hazardous materials 

spill and will have readily available the necessary contact information for Local, 

 

7 The primary focus of the Tier 4 program is the transfer of catalyst based emission control technologies developed for 

on-highway diesel engines to nonroad engines. EPA Clean Air Nonroad Diesel - Tier 4 Final Rule, June 29, 2004. 
 

State, and Federal emergency responders as well as emergency response 

contractor resources. Facility employees, working with NSR environmental staff 

and Local authorities, will have around the clock access to these emergency 

response resources. NSR will shift some of their domestic intermodal capacity from 

the Forrest IMF to the Memphis Regional IMF. 

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Memphis Regional Intermodal Facility xvi 

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TABLE OF CONTENTS 

Table of Contents 

SUMMARY ......................................................................................................................... i

LIST OF ACRONYMS ................................................................................................. vii

ENVIRONMENTAL COMMITMENTS ............................................................................. xiii

1 PURPOSE AND NEED FOR ACTION ........................................................................... 1

1.1. Introduction .......................................................................................................... 1

1.2. Project Background ............................................................................................. 2

1.3. The Need for the Proposed Action ..................................................................... 3

1.4. Project Purpose .................................................................................................... 7

1.5. Consistency with Plans ....................................................................................... 7

1.6. Purpose and Need Conclusion ......................................................................... 11

2 ALTERNATIVES ............................................................................................................ 1

2.1 Proposed Action ................................................................................................... 1

2.2 No-Build Alternative .............................................................................................. 6

2.3 Build Alternatives Considered in the Planning Process ................................... 7

2.3.1 Alternatives Reviewed But Eliminated From Further Consideration .............. 10

2.3.1.1 Alternative 2: East Rossville IMF (Windyke Property) ............................. 10

2.3.1.2 Alternative 3: Expansion of Existing Facility (Forrest IMF) ...................... 11

2.3.1.3 Alternative 4: IMF on Vulcan Property ..................................................... 11

2.3.1.4 Alternative 5: IMF on Pictsweet Property ................................................ 12

2.3.1.5 Alternative 6: Intermodal Gateway at Memphis Pidgeon Park ................ 13

2.3.2 Build Alternative ............................................................................................. 13

2.3.2.1 Refinement of Alternative ........................................................................ 13

2.3.2.2 Description of Build Alternative ............................................................... 14

2.3.3 Comparison of Alternatives ............................................................................ 18

2.4 Identification of Build Alternative ........................................................................ 1

3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION ...................... 2

3.1. Land Use ............................................................................................................... 3

3.1.1 Existing Land Uses .......................................................................................... 3

3.1.2 Land Use Impacts ............................................................................................ 6

3.2 Farmland Impacts ................................................................................................. 8

3.2.1 Existing Farmland Uses ................................................................................... 9

3.2.2 Farmland Impacts .......................................................................................... 10

3.3 Transportation Impacts ...................................................................................... 10

3.3.1 Freight Transportation .................................................................................... 10

3.3.2 Traffic Analysis ............................................................................................... 12

3.3.3 Traffic Impact Evaluation ............................................................................ 13

3.3.3.1 Existing Conditions .................................................................................. 15

3.3.3.2 Background Conditions ........................................................................... 16

3.3.3.3 Future Conditions .................................................................................... 18

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TABLE OF CONTENTS 

3.3.3.4 Recommendations .................................................................................. 26

3.3.3.5 Conclusion ............................................................................................... 28

3.4. Social Impacts .................................................................................................... 29

3.4.1 Existing Social Conditions .............................................................................. 29

3.4.2 Environmental Justice .................................................................................... 32

3.4.2.1 Low-Income Populations ......................................................................... 33

3.4.2.2 Minority Populations ................................................................................ 35

3.4.3 Existing Community Services ......................................................................... 36

3.4.4 Social Impacts ................................................................................................ 37

3.4.5 Security Impacts ............................................................................................. 38

3.5. Displacements .................................................................................................... 38

3.6. Economic Impacts ............................................................................................. 38

3.6.1 Existing Economic Conditions ........................................................................ 38

3.6.2 Economic Impacts .......................................................................................... 39

3.7. Air Quality Impacts ............................................................................................ 40

3.7.1 Existing Air Quality Designation ..................................................................... 41

3.7.2 Conformity Analysis ....................................................................................... 41

3.7.3 Evaluate Air Quality ........................................................................................ 43

3.7.3.1 Mobile Source Air Toxics (MSATs) ............................................................. 45

3.7.4 Air Quality Impacts ......................................................................................... 58

3.7.5 Greenhouse Gas Emissions/Climate Change ................................................ 59

3.8. Noise Impacts ..................................................................................................... 60

3.8.1 Fundamentals of Sound and Noise ................................................................ 61

3.8.2 Criteria for Determining Impacts..................................................................... 63

3.8.2.1 Future Noise Level Analysis .................................................................... 68

3.8.2.2 Noise Impact Analysis for Design Year 2032 .......................................... 68

3.8.3 Noise Abatement Measures Evaluation ......................................................... 70

3.8.4 Design Year (2032) No-Build Alternative Noise Environment ........................ 75

3.9. Cultural Resource Impacts ................................................................................ 75

3.9.1 Historic Architectural Resources .................................................................... 77

3.9.2 Archaeological Resources ............................................................................. 79

3.9.3 Section 106 Coordination ............................................................................... 80

3.10. Recreational Resource Impacts ...................................................................... 82

3.11. Section 4(f)........................................................................................................ 82

3.12. Natural Resources Impacts ............................................................................. 82

3.12.1 Terrestrial Resources ................................................................................... 83

3.12.2 Water Quality and Aquatic Resources ......................................................... 88

3.12.3 Wetland Resources ...................................................................................... 94

3.12.4 Channelization of Streams ........................................................................... 96

3.12.5 Floodplain Impacts ....................................................................................... 96

3.12.6 Aquifer Impacts .......................................................................................... 101

3.12.7 Stormwater Impacts ................................................................................... 109

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3.12.8 Threatened and Endangered Species........................................................ 114

3.12.8.1 State-Listed Species within Four Miles of Project ............................... 115

3.12.8.2 Summary ............................................................................................. 116

3.12.9 Invasive Species ........................................................................................ 117

3.12.10 Wild and Scenic River .............................................................................. 117

3.12.11 Exceptional Tennessee Waters or Outstanding National Resource Waters

 .............................................................................................................................. 117

3.12.12 Environmental Permits ............................................................................. 118

3.13. Geological and Soil Impacts ......................................................................... 119

3.13.1 Geology ...................................................................................................... 119

3.13.2 Soils ........................................................................................................... 120

3.13.3 Geologic Hazards ....................................................................................... 121

3.13.4 Seismic ....................................................................................................... 121

3.13.5 Geologic or Soil Impacts ............................................................................ 121

3.14. Visual Impacts ................................................................................................ 123

3.14.1 Existing Visual Environment ....................................................................... 123

3.14.2 Visual Impacts ............................................................................................ 123

3.15. Energy Impacts .............................................................................................. 126

3.15.1 Construction ............................................................................................... 126

3.15.2 Facility Infrastructure and Operations ........................................................ 127

3.15.3 Train and Truck Use ................................................................................... 127

3.16. Hazardous Materials Impacts ........................................................................ 128

3.16.1 Potential Hazardous Material Sites ............................................................ 128

3.16.2 Potential Hazardous Material in Transit ..................................................... 129

3.16.3 Potential Hazardous Material Impacts........................................................ 132

3.17. Pedestrian and Bicycle Impacts ................................................................... 136

3.18. Indirect and Cumulative Impacts ................................................................. 137

3.18.1 Indirect and Cumulative Impacts to Land Use............................................ 139

3.18.1.1 Indirect Impacts ................................................................................... 139

3.18.1.2 Cumulative Impacts ............................................................................. 142

3.18.2 Indirect and Cumulative Impacts to Transportation .................................... 147

3.18.2.1 Indirect Impacts ................................................................................... 147

3.18.2.2 Cumulative Impacts ............................................................................. 152

3.18.3 Indirect and Cumulative Impacts to Social and Community Resources ..... 164

3.18.3.1 Indirect Impacts ................................................................................... 164

3.18.3.2 Cumulative Impacts ............................................................................. 165

3.18.4 Indirect and Cumulative Impacts to Economic Resources ......................... 166

3.18.4.1 Indirect Impacts ................................................................................... 166

3.18.4.2 Cumulative Impacts ............................................................................. 168

3.18.5 Indirect and Cumulative Impacts to Terrestrial Resources......................... 169

3.18.5.1 Indirect Impacts ................................................................................... 169

3.18.5.2 Cumulative Impacts ............................................................................. 172

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3.18.6 Indirect and Cumulative Impacts to Wetlands, Water Quality and Aquatic 

Resources ............................................................................................................. 173

3.18.6.1 Indirect Impacts ................................................................................... 173

3.18.6.2 Cumulative Impacts ............................................................................. 176

3.18.7 Indirect and Cumulative Impacts to Floodplains......................................... 185

3.18.7.1 Indirect Impacts ................................................................................... 185

3.18.7.2 Cumulative Impacts ............................................................................. 185

3.18.8 Indirect and Cumulative Impacts to Noise .................................................. 189

3.18.8.1 Indirect Impacts ................................................................................... 189

3.18.8.2 Cumulative Impacts ............................................................................. 189

3.18.9 Indirect and Cumulative Impacts to Cultural Resources ............................ 190

3.18.9.1 Indirect Impacts ................................................................................... 190

3.18.9.2 Cumulative Impacts ............................................................................. 191

3.18.10 Indirect and Cumulative Impacts from Hazardous Materials .................... 191

3.18.10.1 Indirect Impacts ................................................................................. 191

3.18.10.2 Cumulative Impacts ........................................................................... 192

3.18.11 Indirect and Cumulative Impacts to Visual Effects ................................... 193

3.18.11.1 Indirect Impacts ................................................................................. 193

3.18.11.2 Cumulative Impacts ........................................................................... 193

3.18.12 Indirect and Cumulative Impacts to Air..................................................... 193

3.18.12.1 Indirect Impacts ................................................................................. 193

3.18.12.2 Cumulative Impacts ........................................................................... 194

3.19. Construction Impacts ................................................................................... 197

3.19.1 Maintenance of Traffic and Access ............................................................ 197

3.19.2 Employment Benefits ................................................................................. 198

3.19.3 Waste Disposal .......................................................................................... 198

3.19.4 Utility Relocation ........................................................................................ 199

3.19.5 Discovery of Unknown Archaeological Sites .............................................. 200

3.19.6 Erosion Control .......................................................................................... 200

3.19.7 Air Quality ................................................................................................... 201

3.19.8 Noise .......................................................................................................... 203

3.19.9 Natural Resources ..................................................................................... 206

3.20. Impacts Summary ......................................................................................... 207

4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION ............................... 1

4.1. Project Initiation and Coordination ................................................................... 1

4.1.1 Project Initiation ................................................................................................ 1

4.1.2 Coordination Packages .................................................................................... 1

4.2. Agency Input ........................................................................................................ 4

4.2.1 Initial Agency Coordination .............................................................................. 4

4.2.2 Section 106 Coordination ............................................................................... 10

4.2.3 TESA Process ................................................................................................ 10

4.3. Public Involvement ............................................................................................ 12

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List of Appendices 

Appendix A – Agency Comments ..................................................................................... 1

Appendix B – Section 106 Coordination ........................................................................... 1

List of Figures 

Figure 1-1: Intermodal Facility Operations ....................................................................... 3

Figure 1-2: Density of Highway Freight Movement .......................................................... 4

Figure 1-3: Economic Impacts – Fayette County Intermodal Facility ............................... 5

Figure 1-4: Average Daily Long-Haul Truck Traffic on National Highway System ........... 6

Figure 1-5: Memphis Area Freight Transportation Components ...................................... 7

Figure 1-6: Existing NSR Forrest Yard IMF Aerial ........................................................... 8

Figure 1-7: Forrest IMF Work Layout ............................................................................... 9

Figure 1-8: Location of Satellite Parking Lot near Forrest IMF............................................ 10

Figure 1-9: Warehouse Square Footage Constructed Since 2002 by Zip Code ............ 11

Figure 2-1: NSR Intermodal System ................................................................................ 2

Figure 2-2: Area of Interest .............................................................................................. 2

Figure 2-3: Focus Area .................................................................................................... 3

Figure 2-4: Fayette County Growth Plan .......................................................................... 5

Figure 2-5: Proposed Alternatives with Location Criteria .................................................. 8

Figure 2-6: Alternatives Studied in Fayette County .......................................................... 9

Figure 2-7: Build Alternative 1 ........................................................................................ 15

Figure 2-8: Roads around Build Alternative 1, Memphis Regional IMF .......................... 17

Figure 3-1: Property Attributes for Fayette County .......................................................... 4

Figure 3-2: Town of Rossville Proposed Zoning Annexations Map ................................. 5

Figure 3-3: Project Area on Fayette County Growth Plan ................................................ 9

Figure 3-4: Road Network around Build Alternative ........................................................ 14

Figure 3-5: Memphis Regional IMF Hourly Distribution of Trips on US Hwy 72 ............. 21

Figure 3-6: Projected Traffic on US Highway 72 near Industrial Road ........................... 22

Figure 3-7: 2015 Roadway Volumes Two-Lane Segment US Hwy 72 (1% Growth) ..... 23

Figure 3-8: 2015 Roadway Volumes Two-Lane Segment US Hwy 72 (2.5% Growth) .. 24

Figure 3-9: 2015 Roadway Volumes Four-Lane Segment US Hwy 72 (2.5% Growth) .. 25

Figure 3-10: 2032 Roadway Volumes on Four-Lane Segment US Hwy 72 .................... 26

Figure 3-11: Proposed Improvements to Four-Lane US Hwy 72 .................................... 28

Figure 3-12: Percent Poverty from 2000 Census (Block Group Level) ........................... 34

Figure 3-13: Percent Minority from 2000 Census (Block Group Level) .......................... 36

Figure 3-14: Sensitive Population Locations .................................................................. 45

Figure 3-15: National MSAT Emission Trends 1999 – 2050 for Vehicles Operating on 

Roadways Using EPA's MOBILE6.2 Model .................................................................... 47

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Figure 3-16: FTA Impact Criteria: Graphical .................................................................. 66

Figure 3-17: Noise Receptors Location .......................................................................... 67

Figure 3-18: Memphis Regional IMF Area of Potential Effect ........................................ 78

Figure 3-19: Wetlands and Aquatic Resource Locations ............................................... 84

Figure 3-20: Flood Hazard Area ..................................................................................... 98

Figure 3-21: Mississippi Embayment Area ................................................................... 101

Figure 3-22: West Tennessee Memphis Sand - Major Physiographic Subdivision ...... 102

Figure 3-23: Memphis Sand Layers ............................................................................. 103

Figure 3-24: West Tennessee Memphis Sand Recharge Outcrop Area ...................... 104

Figure 3-25: Location of Wolf River Watershed ........................................................... 112

Figure 3-26: Wolf River Subwatershed 0301 ................................................................ 113

Figure 3-27: Nonconnah Creek Watershed .................................................................. 114

Figure 3-28: Tentative Lighting Plan for Memphis Regional IMF ................................. 125

Figure 3-29: What Moves in Intermodal Containers/Trailers ......................................... 130

Figure 3-30: Development in Front Royal VA ............................................................... 144

Figure 3-31: The Sources of Congestion ..................................................................... 148

Figure 3-36: Improvements to Four-Lane Segment of US Hwy 72 ............................... 151

Figure 3-37: Projected Roadway Volumes on Four-Lane Segment of US Hwy 72 ....... 152

Figure 3-32: Proposed Location of SR-385 .................................................................. 154

Figure 3-33: Proposed Location of Southeast Section of I-269 ................................... 155

Figure 3-34: Proposed Location of I-269 in Mississippi ............................................... 156

Figure 3-35: Chickasaw Trails Industrial Park ............................................................... 158

Figure 3-38: I-69 Corridor Alternative Analysis ............................................................. 160

Figure 3-39: Projected 2020 Tennessee Interstate Highway Congestion ..................... 164

Figure 3-40: Wolf River Watershed ............................................................................... 170

Figure 3-41: Nonconnah Watershed ............................................................................. 170

Figure 3-42: Area Land Use (Percentage) within Drainage Areas ................................ 171

Figure 3-43: Area Land Use (Acres) within Drainage Areas ......................................... 171

Figure 3-44: West Tennessee Watersheds ................................................................... 178

Figure 3-45: Land Use Characteristics of the Wolf River Watershed (HUC 0801210) . 180

Figure 3-46: Land Use Characteristics of the Nonconnah Creek Watershed (HUC 

0801211) ....................................................................................................................... 181

Figure 3-47: Land Use by Percentage for Wolf River Watershed ................................. 182

Figure 3-48: Land Use by Percentage for Nonconnah Watershed ............................... 182

Figure 3-49: FEMA Map Index for Southwest Fayette County ...................................... 186

Figure 3-50: 12-Digit HUC Subwatersheds ................................................................... 188

Figure 3-51: Transportation Energy Use by Transportation Mode ................................ 196

List of Tables 

Table S-1: Potential Impacts of Build Alternative 1 ........................................................... iii

Table 2-1: Site Selection Screening Criteria ..................................................................... 5

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Table 2-2: Summary of Alternatives ........................................................................... 19

Table 3-1: Level of Service (LOS) Index ..................................................................... 15

Table 3-2: Level of Service – Existing Conditions (2009) ........................................... 16

Table 3-3: Level of Service – Background Conditions (2015 and 2032) ..................... 17

Table 3-4: Trips Generated Directly By IMF (2015 and 2032) .................................... 18

Table 3-5: Level of Service – Future Conditions (2015 and 2032) .............................. 19

Table 3-6: Population Data ........................................................................................ 30

Table 3-7: Population Characteristics ........................................................................ 32

Table 3-8: 2015 Design Year VMT Projections on Industrial Road and IMF .............. 49

Table 3-9: Typical Sound Levels Measured in the Environment and Industry ............ 62

Table 3-10: FHWA/TDOT Noise Abatement Criteria for Traffic Noise Impacts .......... 64

Table 3-11: Criteria to Define Impacts Due to Traffic Noise Increases ....................... 64

Table 3-12: FTA Land Use Categories and Metrics for Rail Noise Impact Criteria ..... 65

Table 3-13: Predicted Traffic Noise Results and Summary of Traffic Noise Impacts . 71

Table 3-14: Predicted Rail Noise Results and Summary of Impacts .......................... 72

Table 3-15: Predicted Noise Levels with Berm Installation ........................................ 74

Table 3-16: Impacts to Aquatic Resources ................................................................ 90

Table 3-17: Impacts to Wetlands ............................................................................... 95

Table 3-18: Rare, Threatened and Endangered Species Documented within 4 Miles 

of Project ................................................................................................................... 116

Table 3-19: 2020 Employment Impacts of Memphis Regional IMF .......................... 149

Table 3-20: Indirect Trips Potentially Generated ....................................................... 150

Table 3-21: Standard Noise Emission Levels for Construction Equipment ............... 203

Table 3-22: Predicted Attenuation of Potential Construction Activities ..................... 204

Table 3-23: Summary of Potential Impacts from Build Alternative 1 ........................ 207

Table 4-1: Agency Comments ...................................................................................... 5

Table 4-2: Public Comments Grouped by EA Topics ................................................. 14

Table 4-3: Consolidated Public Comments and Response ........................................ 15

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 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-1 

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1 PURPOSE AND NEED FOR ACTION 

1.1. Introduction 

The Norfolk Southern Railway Company (NSR) proposes 

to construct, own, and operate the Memphis Regional 

Intermodal Facility (Memphis Regional IMF) to improve 

freight transportation capacity in the Memphis, Tennessee 

region. The additional capacity is needed to meet growing 

freight demand. Anticipated benefits of the project include 

reducing highway congestion, improving highway safety, 

and providing energy efficient alternatives for current and 

future freight transportation. 

In February 2010, Tennessee was awarded funds to 

support the development of this project from the U.S. 

Department of Transportation, Transportation Investment 

Generating Economic Recovery (TIGER) Program as part 

of the American Recovery and Reinvestment Act (ARRA) 

of 2009. This project is subject to the requirements of the 

National Environmental Policy Act of 1969 (NEPA) as a 

result of this funding.8 The U.S. Department of 

Transportation (DOT), Federal Railroad Administration 

(FRA) and Tennessee Department of Transportation 

(TDOT) are the lead agencies for the proposed project. 

The DOT Federal Highway Administration (FHWA), 

Mississippi Department of Transportation, and U.S. Army 

Corps of Engineers (USACE) are Cooperating Agencies. 

This Environmental Assessment (EA) was prepared to 

comply with NEPA requirements.9 NEPA requires that 

projects receiving Federal funding or requiring Federal 

actions (e.g., permits) undergo an environmental review 

process. An EA is prepared if it is unknown whether a 

project has the potential to significantly impact 

environmental resources. If the EA identifies potentially 

significant impacts, then an Environmental Impact 

Statement (EIS) must be prepared. 

An EA identifies alternatives that meet the project’s 

purpose and need, which may include identifying a 

preferred alternative; may provides an assessment of 

effects both positive and negative on the natural and built 

environment of the alternatives selected to move forward in 

NEPA; and identifies measures to avoid, minimize, or 

mitigate negative effects. 

 

8 42 United States Code (U.S.C.) Sections 4321-4347. 

9 Council on Environmental Quality (CEQ), Regulations for Implementing the Procedural Provisions of the National 

Environmental Policy Act, 40 Code of Federal Regulations (C.F.R.) Parts 1500-1508; TDOT, Tennessee Environmental 

Procedures Manual: Guidelines for Preparing Environmental Documentation for Federally Funded and State Funded 

Transportation Projects, April 2007.
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-2 

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The purpose of the EA is to disclose the effects of a project 

at a stage in the development process when decisionmaking can still be shaped by the environmental analysis 

and by the comments of agencies and public reviewers. If 

it is determined the proposed project would not have a 

significantly adverse effect on the environment, then each 

involved Federal agency taking an action regarding the 

project would issue a Finding of No Significant Impact 

(FONSI). 

NEPA requires that one or more Federal agencies (lead 

agencies) take responsibility for overseeing the 

environmental review process. For the preparation of the 

EA for the Memphis Regional IMF project, the FRA is 

serving as the lead Federal agency. TDOT serves as the 

lead State agency. 

1.2. Project Background 

Intermodal freight transportation is a method of moving 

freight from origin to final destination using two or more 

transportation modes. Intermodal improves transportation 

efficiency by allowing for the most efficient mode of 

transport for each segment of a shipment of goods in a 

trailer or container.10 For the proposed project, freight 

shipments would use rail for long distances and highway 

for local pick-ups and deliveries. 

An intermodal facility (IMF) is a terminal for transferring 

freight from one transportation mode to another, in this 

case between trains and trucks, without handling of the 

freight itself when changing modes. Figure 1-1 illustrates 

the basic freight transportation process via intermodal 

methods. 

The FHWA Freight Analysis Framework (FAF) forecasts 

that the tons of freight transported will likely almost double 

by 2035 from its 2006 level.11 The FAF identified primary 

drivers of this growth as economic activity, population, and 

international shipments. 

During the 1980 to 2005 period, gross domestic product 

(GDP) doubled and foreign trade quadrupled reflecting an 

unprecedented growth in global interconnectivity. The U.S. 

population grew by 30% from 1980 to 2005.12 In 

particular, population in the Southern region of the U.S. 

 

10 John Frittelli, “Intermodal Connectors: A Method for Improving Transportation Efficiency?,” (Washington D.C.: 

Congressional Research Service, 2003). 

11 FHWA, “Freight Analysis Framework, Version 2.2”, 2002 http://ops.fhwa.dot.gov/freight/freight_analysis/faf/index.htm 

12 U.S. Census Bureau, “The 2010 Statistical Abstract, The National Data Book,” 14 Dec 2009, 

http://www.census.gov/compendia/statab/
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-3 

6/30/2010 

grew by 45%. 

Figure 1-1: Intermodal Facility Operations 

According to FHWA analysis, intermodal transportation 

would grow at a faster rate than other transportation 

methods, except for air.13 Intermodal growth is also driven 

by factors such as highway congestion, fuel prices, and 

labor pool, as well as improvements in shipping services 

and efficiencies between different transportation modes. 

With the current economic downturn, the transport of 

trailers or containers by rail in the first 49 weeks of 2009 

was down nationally approximately 15% from 2008.14 In 

the Memphis area, the existing NSR Forrest IMF 

operational data indicate only an 11% decrease for the 

same approximate time frame. In addition, the Association 

of American Railroads (AAR) continues to predict that 

intermodal freight transport will see growth in the years 

ahead.15 

1.3. The Need for the Proposed Action 

Existing infrastructure is not adequate to serve future 

transportation capacity needs in the Memphis region. 

Figure 1-2 depicts the density of highway freight movement 

 

13 FHWA, Office of Freight Management and Administration, “Freight Facts and Figures 2007,” (Washington D.C.: 

FHWA). 

14 AAR, “AAR Reports Weekly U.S. Rail Freight Traffic Remains Down,” 17 Dec 2009 

http://www.aar.org/NewsAndEvents/PressReleases/2009/12_WTR/121709_RailTraffic.aspx. 

15 AAR, November 2009. 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-4 

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between the central southeast and the northeast. The 

darker sections show areas of higher density of freight 

movements.16 As indicated, a freight transportation 

bottleneck exists between the Memphis region and the 

Northeast U.S. The Memphis Regional IMF would help 

alleviate this bottleneck with its increased intermodal 

service capacity. To meet the increased demand for 

capacity, NSR estimates a need for a new facility that can 

perform 327,000 annual lifts of containers and trailers 

between trucks and trains.17 

Figure 1-2: Density of Highway Freight Movement 

The estimated number of required annual lifts for the 

Memphis Regional IMF is based on the following NSR 

annual projections: 

 To convert 187,000 truckloads from highway to 

rail, consisting of 54,000 truckloads coming to the 

Memphis area from the Northeast U.S. and 

133,000 truckloads going to the Northeast U.S. 

 

16 NSR, “Form: 8-K,”12 Jun. 2007, http://google.brand.edgaronline.com/EFX_dll/EDGARpro.dll?FetchFilingHTML1?SessionID=Ya3uWJ3XXzYY1uh&ID=5241016. 

17 In this context, a “lift” is a trailer or container loaded to a rail car or unloaded from a rail car. 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-5 

6/30/2010 

from the Memphis area.18 

 To handle 79,000 annual empty trailer and 

container movements from the eastern and 

Northeastern U.S. in the Memphis area.19 

The new 266,000 trailers and containers identified above, 

combined with some existing rail traffic volume creates the 

327,000 lift capacity requirement. This projected 

requirement is approximately 2-1⁄2 times the capacity of the 

current NSR Forrest Intermodal Facility (Forrest IMF) 

located in Memphis. 

Based on a regional economic benefits study, the freight 

transportation demand in the area and the Memphis 

Regional IMF can contribute to a cumulative economic 

impact of $2.7 billion by 2020, and to employment growth of 

6,186 new or benefited jobs in the same period.20

 New or 

benefited jobs are estimated based on employment data from 

existing NSR IMFs in other locations. Figure 1-3 illustrates 

potential economic impacts based on the IMF being located in 

Fayette County.21 

Figure 1-3: Economic Impacts – Fayette County Intermodal Facility 

 

18 NS Technical Memo, Subject Memphis Regional Intermodal Facility –Traffic Growth Forecast dated January 15, 2010.

19 NS Technical Memo, Subject Memphis Regional Intermodal Facility –Traffic Growth Forecast dated January 15, 2010. 

20 Insight, May 2009. 

21 Insight, May 2009. 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-6 

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Diverting cargo transport from highway to rail would reduce 

future truck traffic by an estimated 186 million loaded truck 

vehicle miles per year on highways between Memphis and 

the Northeast, which is anticipated to contribute to improved 

public safety and air quality through reduced highway 

congestion.22 Reduction in highway congestion is a key 

factor in increasing safety on roads. A quarter of 

congestion problems are caused by traffic incidents such 

as crashes, stalled vehicles, and debris on the road.23 

The AAR estimates that on average, moving freight by rail 

as compared with moving freight by truck reduces 

greenhouse gas (GHG) emissions by 75%. Therefore, if 

just 10% of the long-distance freight moving by truck 

transferred to rail, annual GHG emissions would decline by 

more than 12 million tons.24

As illustrated in Figure 1-4, FHWA predicts increases in 

daily long-haul truck traffic on the I-40 and U.S. Highway 

78 corridors across Tennessee and Mississippi from 2002 

to 2035.25 

Figure 1-4: Average Daily Long-Haul Truck Traffic on National Highway System 

The long-haul truck productivity has decreased since 2002 

due to a number of factors including congestion, fuel costs 

and regulation changes.26 The Memphis Regional IMF 

would transfer highway cargo to rail cargo at an estimated 

rate of 327,000 lifts annually, reducing the number of 

required long-haul trucks. A train loaded with containerize 

 

22 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010.. 

23 FHWA, “Describing the Congestion Problem,” 8 Jun, 2009 http://www.fhwa.dot.gov/congestion/describing_problem.htm. 

24 AAR, November 2009. 

25 FHWA, CMQ and Intermodal Freight Transportation, Oct 2005, 

http://www.fhwa.dot.gov/environment/cmaqpgs/intermodal/index.htm. 

26 ATA, “Truck Weights and Lengths: Assessing the Impacts of Existing Laws and Regulations,” 9 Jul 2008. 

2002 

2035 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-7 

6/30/2010 

freight can carry equivalent to about 280 trucks loaded with 

freight. This estimated annual lifts would be equivalent to 

1,167 trains annually. The Memphis Regional IMF would 

reduce the rate of increase in long-haul truck traffic on 

congested highways, thus reducing damage to highways 

from heavy trucks and improving air quality.27

1.4. Project Purpose 

The primary purpose of the proposed Memphis Regional 

IMF project is to meet current and future demand for 

intermodal (rail/truck) transportation in the Memphis region 

through available expanded capacity. NSR would build, 

own, and operate the Memphis Regional IMF. Its location 

relative to projected future growth in the Memphis area is a 

critical component to satisfy the project’s purpose. 

1.5. Consistency with Plans 

Figure 1-5 provides an overview of the freight 

transportation infrastructure components in the Memphis 

area.28 

Figure 1-5: Memphis Area Freight Transportation Components

The Memphis Urban Area 2030 Long-Range 

Transportation Plan indicates that the NSR Memphis rail 

line is a rail traffic congestion bottleneck in the NSR 

network providing justification for the proposed facility in 

the Memphis region. “Bottleneck” in this context is an area 

 

27 FHWA, “CMQ and Intermodal Freight Transportation,” Oct 2005, 

http://www.fhwa.dot.gov/environment/cmaqpgs/intermodal/index.htm.

28 Memphis and Shelby County Department of Regional Services, “Memphis MPO Transportation Plans, Data and 

Maps,” 23 Dec 2009 http://www.dpdgov.com/(3wxqzd55akajl435hhihjn55)/RS/RS_content.aspx?id=305. 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-8 

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of rail traffic congestion caused by a restriction in capacity. 

National congestion estimates indicate that bottlenecks 

account for 40% of traffic congestion.29

The TDOT I-40/I-81 Corridor Feasibility Study dated April 

2008 discusses how freight movement and intermodal 

facilities could reduce congestion in this corridor.30 NSR 

proposes to construct the Memphis Regional IMF to 

address the projected future freight transportation needs in 

the Memphis region. This project is consistent with State, 

regional, and local planning efforts. 

The existing NSR Forrest IMF located within the Memphis 

city limits, is operating at or over its design capacity. The 

Forrest IMF performed 130,198 intermodal lifts in 2008, 

approximately twice its 1998 volume. The lack of capacity 

has prevented NSR from pursuing additional freight 

haulage opportunities. Physical space limitations prevent 

expansion of the Forrest IMF and thus restrict any further 

increase in volume. Expansion of the Forrest IMF is not 

feasible because the site is bounded by Spottswood 

Avenue on the south and the NSR mainline and a city 

street on the north, Figure 1-6.31 The entire area is within 

an urban setting. 

Figure 1-6: Existing NSR Forrest Yard IMF Aerial

For efficiency, intermodal operations prefer to lift a 

container or trailer from a railcar and place it directly on a 

trailer chassis. The container or trailer is then parked in 

 

29 Cambridge Systematics, Inc., “Traffic Congestion and Reliability: Trends and Advanced Strategies for Congestion 

Mitigation, prepared for the Federal Highway Administration,” 1 Sept 2005. 

30 TDOT I-40/I-81 Corridor Feasibility Study Task 3.0 Multi-Modal Solutions, Technical Memorandum, April 2008. 

31 Base map from Google Earth, 8 Jul 2008, http://earth.google.com/. 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-9 

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the adjacent terminal parking lot awaiting truck pick-up. In 

reverse, when a container or trailer is delivered by truck, 

the preferred operation is to lift the trailer or the container 

from the trailer chassis and place it directly on the train. 

The trucks retrieving or delivering containers or trailers to 

the IMF can arrive at any time of the day. 

At the Forrest IMF (Figure 1-7), the current freight volume 

has been achieved through various expensive and 

inefficient maneuvers including: 

Figure 1-7: Forrest IMF Work Layout 

 Stacking Containers. Containers are unloaded and 

then stacked on the ground up to three high until 

they are lifted again to be placed on chassis so 

they can leave the facility. Stacking containers 

increases the number of containers which can be 

stored in an area, but increases the energy 

consumption, time, and cost by requiring containers 

to be handled multiple times when moving them. 

 Off-site Parking. In 2008, a total of 14,600 

containers and trailers were unloaded from rail 

cars, placed on chassis and immediately moved 2.5 

miles via city streets to a 7.3-acre satellite parking 

lot (1516 Rozelle Street) where they were held until 

customer pickup, as shown in Figure 1-8.32 This 

 

32 Address from NSR Intermodal. Base map from Google Earth, 8 Jul 2008 http://earth.google.com/. 
 1 PURPOSE AND NEED FOR ACTION 

increases the container and trailer storage area, 

and increases operational costs due to transport to 

the off-site parking lot and due to having to own, 

operate, and maintain the satellite parking lot. 

Transferring these trailers and containers to off-site 

parking along city streets also results in increased 

safety and congestion problems surrounding the 

facility. 

 Off-site Rail Car Storage. Empty rail cars to be 

loaded at Forrest IMF are stored on a weekly basis 

in various sidings 110 to 125 miles away awaiting 

loading later in the week at the Forrest IMF. This 

lack of track capacity at Forrest IMF increases 

energy consumption and cost since additional car 

handling and train movements are required to store 

the cars at a distant location. 

The above constraints and inefficiencies prompted NSR to 

begin developing plans for a new IMF in the Memphis 

region to meet capacity demand. The target area for 

locating the new IMF has been in Fayette County, 

Tennessee, southeast of Memphis. 

Figure 1-8: Location of Satellite Parking Lot near Forrest IMF 

Memphis Regional Intermodal Facility 1-10 

6/30/2010 
 1 PURPOSE AND NEED FOR ACTION 

Memphis Regional Intermodal Facility 1-11 

6/30/2010 

The existing NSR mainline traverses southern Fayette 

County. This rail line is NSR’s only route in the Memphis 

region. Figure 1-9 shows warehouse development trends 

in the region since 2002, illustrating growth in development 

south and east of Memphis.33 

Locating the Memphis Regional IMF near the areas of 

projected warehouse and industrial growth is essential for 

developing an efficient rail intermodal freight service 

alternative to highway freight transport and is therefore a 

critical component to satisfy the project’s purpose. 

Figure 1-9: Warehouse Square Footage Constructed Since 2002 by Zip Code 

1.6. Purpose and Need Conclusion 

With existing limitations on freight transportation capacity 

and the projected doubling of intermodal traffic in the 

Memphis area, larger and more efficient intermodal 

facilities need to be constructed. The Memphis Regional 

IMF would allow for the efficient movement of goods to and 

from the Northeastern U.S. by creating additional IMF 

capacity in the Memphis region. An additional benefit of 

the conversion of truck traffic to rail is the reduction of 

highway congestion, wear and tear on roads, carbon 

emissions, and traffic accidents. 

 

33 Modalgistics using data from CB Richard Ellis. 

Likely Future 

Growth Area 

Forrest IMF 

In Square Feet 
 1 PURPOSE AND NEED FOR ACTION 

Blank Page 

Memphis Regional Intermodal Facility 1-12 

6/30/2010 
 2 ALTERNATIVES 

Memphis Regional Intermodal Facility 2-1 

6/30/2010 

2 ALTERNATIVES 

A number of potential build alternative locations were 

studied for the Memphis Regional IMF. This section 

summarizes the process used to select the build 

alternative locations to bring forward in the EA. As 

required by NEPA and applicable regulations, reasonable 

alternatives must be reviewed and a Build Alternative(s) 

and a No-Build (or No Action) Alternative must be fully 

evaluated in the EA. In addition, alternatives that were 

identified and considered, but did not meet the Purpose 

and Need for the project and/or resulted in potential 

impacts that were substantially greater than other build 

alternatives are briefly discussed. 

2.1 Proposed Action 

NSR would build, own, and operate the Memphis Regional 

IMF. To meet the operational requirements, the following 

main components needed are: 

 Tracks connecting the Memphis Regional IMF 

site to the NSR mainline; 

 Six-4,050 foot long pad tracks; 

 Support yard with 34,500 feet of track; 

 Paved areas for parking approximately 2,200 

trailers and containers on chassis; 

 Administration, maintenance, and operations 

buildings; and 

 Equipment maintenance pad and other related 

facilities. 

A suitable location is a critical requirement to satisfy the 

Memphis Regional IMF purpose and need. In locating 

potential facility site in the Memphis region in the Memphis 

region, NSR reviewed the freight volumes (Figure 1-2), the 

warehouse growth areas (Figure 1-9), and the existing NSR 

rail system (Figure 2-134). 

The area reflecting this growth and potential demand for 

improved intermodal facilities was found to be south and 

east of Memphis as reflected in the primary area of interest, 

as shown in Figure 2-2. 

 

34 NSR, “Intermodal System Map,” http://www.nscorp.com/nscintermodal/Intermodal/System_Info/Terminals/. 
 2 ALTERNATIVES 

Figure 2-1: NSR Intermodal System 

Within this area of interest, NSR conducted a more detailed 

analysis for locations that would meet these market 

demands and were sufficiently close to the existing NSR 

mainline. 

Figure 2-2: Area of Interest 

Area of Interest 

NSR Mainline 

Memphis Regional Intermodal Facility 2-2 

6/30/2010 
 2 ALTERNATIVES 

Memphis Regional Intermodal Facility 2-3 

6/30/2010 

Ultimately, NSR focused on the area shown in Figure 2-3. 

The review also considered other criteria important to a 

safe, environmentally sound, and efficient operation. Such 

criteria included avoidance or minimization of impacts to 

natural resources, sufficient land, proximity to NSR mainline 

and highway infrastructure, and other efficiency factors. 

These criteria are outlined below and applied to each 

alternative in Section 2.3. 

Figure 2-3: Focus Area 

 Sufficient Land. Sufficient land is necessary to 

develop a facility, which can meet intermodal 

demand and support the infrastructure, operations, 

and storage requirements. The site needs to be a 

rectangular tract consisting of approximately 380 

useable acres (approximately 7,000 feet long by 

2,400 feet wide). 

 Proximity to Rail Infrastructure. The project must be 

located near the NSR mainline, as shown on 

Figures 2-2 and 2-3.35 The proposed location on 

the southeast side of Memphis would reduce rail 

transit time along the NSR’s mainline into the 

Memphis. 

 Proximity to Highway Infrastructure. The proposed 

site must be located in proximity to adequate 

highway infrastructure. In Tennessee, the NSR rail 

line parallels State Route (SR) 57 (Figures 2-2 and 

2-3). SR-57 is designated as a rural minor arterial. 

The closest U.S. Highway or Interstate to the 

 

35 Base map for Figure 2-2 and 2-3 from TDOT, Official Tennessee Transportation Map. 

 NSR Mainline 

Wolf River 

Focus Area
 2 ALTERNATIVES 

Memphis Regional Intermodal Facility 2-4 

6/30/2010 

planned project is U.S. Highway (US Hwy) 72, 

which is designated as a rural principle arterial. This 

roadway, combined with completion of SR-38536

and the potential for I-69/I-26937 around Memphis, 

provides favorable highway routes for the Fayette 

County location. 

 Location. The proposed IMF must be located in an 

area convenient for industrial and commercial 

economic activities. The facility’s projected 

customer base is generally moving eastward and 

southward from the Memphis metropolitan area. 

Locating the new facility southeast of Memphis 

matches this growth pattern. Specific areas 

reviewed fall within the Rossville Urban Growth 

Boundary (UGB) (Figure 2-4).38 

By using the above criteria, the IMF should be able to 

realize the goals of efficiency and transportation 

optimization.39 To narrow the alternative locations for the 

Memphis Regional IMF, NSR developed criteria against 

which to review the alternatives. Table 2-1 summarizes 

these screening criteria and the rationale used to rank the 

various alternatives. For an alternative to be considered 

viable, the first four criteria must be met. The remaining 

criteria affect the evaluation of each alternative based on 

the relative impact they impose compared to other 

alternatives. 

The table lists the primary distinguishing criteria based 

upon information available for each alternative to date. As 

appropriate pursuant to the NEPA, a full analysis will be 

addressed in subsequent sections of this document. 

 

36 TDOT SR-385 website, http://www.tdot.state.tn.us/sr385/. 

37 TDOT, “Newsletter #7 Alignment Selected For I-69, Section 9 From Hernando, MS To Millington, TN,” December 2004 

http://www.tdot.state.tn.us/i69/segment9/newsletters/1204.pdf.

38 Fayette County Tennessee, “Fayette County Growth Plan Map,” August 2003, 

http://www.fayettetn.us/FC%20Growth%20Plan%202.htm. 

39 DOT, NHS Intermodal Freight Connectors; A Report to Congress, December 2000. 
 2 ALTERNATIVES 

Figure 2-4: Fayette County Growth Plan 

Table 2-1: Site Selection Screening Criteria

1* Sufficient Land: Alternative must have sufficient land to allow for construction of 

suitably-sized facility with appropriate shape and configuration. 

2* Proximity to NSR Rail Infrastructure: Alternative must be located near NSR mainline 

to facilitate efficient rail access. 

3* 

Proximity to Highway Infrastructure: Alternative must be located in proximity to an 

adequate highway network. Sites must have adequate infrastructure and be able to 

accommodate expected IMF traffic. 

Memphis Regional Intermodal Facility 2-5 

6/30/2010 
 2 ALTERNATIVES 

Memphis Regional Intermodal Facility 2-6 

6/30/2010 

Table 2-1: Site Selection Screening Criteria

4* Location: Alternative must be a location that can efficiently serve industrial and 

commercial growth and be compatible with existing or proposed land use in the area. 

5 

Natural Resources Impacts: Alternative should avoid and/or minimize impacts to 

natural resources. Sites that have adverse impacts that cannot be mitigated would be 

considered less desirable. 

6 

Cultural, Historic, and Social Resource Impacts: Alternative should avoid and/or 

minimize impacts to cultural, historical, and socioeconomic resources. Sites that have 

impacts that cannot be mitigated would be considered less desirable. 

* Denotes criteria that must be clearly met for an alternative to be considered viable. 

2.2 No-Build Alternative 

The No-Build Alternative represents future conditions in the 

project area without increasing intermodal capacity. The 

No-Build Alternative serves as the benchmark against 

which the proposed Build Alternatives are compared. 

Adopting the No-Build Alternative means NSR would have 

to continue to use the existing Forrest IMF in Memphis 

without modification or expansion. Growth in the freight 

market would be met by increased highway truck traffic 

rather than increased rail-truck intermodal service. Without 

adequate rail-truck intermodal service, some industries 

would be less likely to locate in the area thus hampering 

overall economic growth. Intermodal operations can 

increase transportation efficiency, reduce emissions 

including Greenhouse Gas (GHG) emissions, and improve 

energy efficiency as freight transport by rail is 

approximately three and a half times more fuel efficient 

than transport by trucks.40 With the No-Build Alternative, 

no increase in these benefits from a larger and more 

efficient IMF would be realized. 

The No-Build Alternative would not cause any immediate 

direct impacts to the human or natural environment in the 

project area. However, the No-Build Alternative would fail 

to satisfy the demand for much needed additional IMF 

capacity within the Memphis region. A NSR regional truck 

demand study41 identified a substantial demand for 

increased intermodal service between the Memphis region 

and the Northeast. Using the existing Forrest Yard IMF 

and/or other existing IMFs in other regions would not 

 

40 AAR 2009, November 2009. 

41 NS Technical Memo, Subject Memphis Regional Intermodal Facility –Traffic Growth Forecast dated January 15, 2010. 
 2 ALTERNATIVES 

adequately support the Memphis market.42 Therefore, the 

No-Build Alternative does not meet the Purpose and Need 

of the undertaking.

2.3 Build Alternatives Considered in the 

Planning Process 

Between 2003 and 2009, six alternatives were evaluated 

for the Memphis Regional IMF project: 

 Alternative 1 – Memphis Regional IMF (Build 

Alternative 1) 

 Alternative 2 – East Rossville IMF (Windyke 

Property) 

 Alternative 3 – Expand Forrest IMF 

 Alternative 4 – IMF on Vulcan Property 

 Alternative 5 – IMF on Pictsweet Property 

 Alternative 6 – Intermodal Gateway at Memphis 

Pidgeon Park 

Figure 2-5 shows the location of alternatives that were 

considered. Alternatives 3 and 6 are within Shelby County, 

inside Memphis. The remaining four alternatives are in 

Fayette County as shown in Figure 2-6. All of the build 

alternatives considered would require construction of a 

new intermodal facility of a similar size and design, 

capable of meeting the operational requirements detailed 

in Section 2.1. A more detailed description of these 

alternatives is provided in the following sections. 

 

42 IHS Global Insight data, modified with proprietary data shared by four large NSR domestic truckload customers. 

Memphis Regional Intermodal Facility 2-7 

6/30/2010 
2 AL

Figure 2-5: Proposed Alternatives with Location Criteria 

Memphis Regional Intermodal Facility 6/30/2010 
Figure 2-6: Alternatives Studied in Fayette County 

Altern

Alternative 1 – Mem

(Ada

Alternative 2 – E. RoAlternative 3 – ExpaAlternative 4 – VulcAlternative 5 – PictsAlternative 6 – PidgNote – Alternatives shown on this map (See Figure 2-5 for t

Memphis Regional Intermodal Facility 6/30/2010 
2 ALTERNATIVES

2.3.1 Alternatives Reviewed But Eliminated From Further 

Consideration 

As discussed below, Alternatives 2, 3, 4, 5, and 6 were 

evaluated using the Table 2-1 criteria and eliminated from 

further consideration because they: 

 Failed to meet one or more of the critical evaluation 

factors which must be met for a project to be 

considered viable, or 

 Were judged inferior to Build Alternative 1 with 

respect to potential impacts to natural resources 

and cultural resources, or have undesirable 

operating costs or inefficiencies. 

2.3.1.1 Alternative 2: East Rossville IMF (Windyke 

Property) 

Alternative 2 (approximately 795-acre site) would include 

constructing an IMF along the south side of the mainline 

tracks on the east side of Rossville (Figure 2-6), just north 

of SR-57. This location satisfies the railroad’s needs for 

adequate acreage and facility layout. Due to its proximity 

to NSR mainline tracks, East Rossville is a suitable 

location to meet rail transit requirements. However, use of 

the East Rossville IMF would increase highway traffic 

volume for the 7-mile section of SR-57 to SR-385, which 

would involve routing truck traffic through the City of 

Rossville. There has been strong opposition to increasing 

traffic along SR-57 from the local community and other 

stakeholders. Also, this site is located at the maximum 

distance from Memphis that is considered efficient for 

truck-train transfer to occur within the Memphis market. 

For the East Rossville site, the lead tracks to the 

development would be located within the Wolf River 

floodplain. Overall, the site topography is such that the 

northern portion of the property would need to be filled 

while a substantial cut would be needed along the south 

side of the property to bring the site to the required grade. 

The overall site elevation should result in good sub-grade 

conditions compared to the other low-lying sites 

(Alternatives 4 and 5) adjacent to SR-57. Environmental 

impacts would include several streams and wetlands and 

potentially impacting a known Civil War earthwork. This 

site would be up-stream of the William Clark Conservation 

Area and between sections of the Wolf River designated 

Memphis Regional Intermodal Facility 2-10

6/30/2010 
2 ALTERNATIVES

Memphis Regional Intermodal Facility 2-11

6/30/2010 

as Exceptional Tennessee Waters (ETW).43 The potential 

wetland impacts for this location are less than the impacts 

for Alternative 4, Vulcan Property, and Alternative 5, 

Pictsweet Property. 

Alternative 2 appears to be a viable alternative since it 

meets the first four criteria in Table 2-1 in supporting the 

Purpose and Need for the project. However, given the 

potential environmental impacts on area wetlands, the 

William Clark Conservation Area and sections of the Wolf 

River designated as ETW, Alternative 2 has been 

eliminated from consideration as the potential 

environmental impacts are more substantial than those of 

Alternative 1. 

2.3.1.2 Alternative 3: Expansion of Existing Facility (Forrest 

IMF) 

Alternative 3 would expand the existing Forrest IMF to 

create additional intermodal capacity. NSR currently 

operates the Forrest IMF five miles east of downtown 

Memphis (Figure 2-5). The IMF shares Forrest Yard with 

other non-intermodal NSR railroad operations, including 

train interchanges with the four other Class I railroads in 

the Memphis area. The Forrest IMF encompasses 

approximately 50 acres owned by NSR. The facility is 

currently operating at or near its capacity. As shown in 

Figure 1-6, industrial development, sports arenas, the NSR 

mainline and residential housing are located to the north of 

the Forrest site thus preventing expansion in that direction. 

The southern boundary of the Forrest IMF facility aligns 

next to Spottswood Avenue. This area includes a fully 

developed community thus preventing any expansion to 

the south. 

Consequently, opportunities for capacity expansion at the 

Forrest IMF do not exist due to its urban location. Since 

Alternative 3 cannot meet the required criteria of sufficient 

land identified in the Purpose and Need for the project, 

Alternative 3 is not viable and has been eliminated from 

further consideration. 

2.3.1.3 Alternative 4: IMF on Vulcan Property 

For Alternative 4, the IMF would be constructed along the 

south side of the mainline tracks in Rossville (Figure 2-6). 

This layout encompasses a tract of land owned by Vulcan 

Materials; therefore, the site is called the Vulcan property. 

This alternative is located about one mile west of Rossville 

 

43 TDEC, “From Hwy 194 (RM 44.4) to RM 56 (1.5 miles downstream of Hwy 57 at Moscow), The Known Exceptional 

Tennessee Waters and Outstanding National Resource Waters,” 7 Nov 2005 http://environmentoline.state.tn.us:7654/pls/enf_reports/f?p=9034:34304:2214091869367932. 
2 ALTERNATIVES

Memphis Regional Intermodal Facility 2-12

6/30/2010 

between the NSR mainline and SR-57. Alternative 4 

presents a feasible location with respect to rail operations; 

however, it includes only 300 acres and would require the 

relocation of existing businesses including a rail served 

stone distribution yard (Vulcan) and a planned-permitted 

asphalt operation. This alternative would increase traffic 

volume along SR-57 for the 3.5 miles between the IMF and 

SR-385. Additional environmental considerations include 

construction in a floodplain and impacts to streams and 

wetlands. 

Alternative 4 is too small of a site and would not allow for 

the construction of an adequate facility layout necessary 

for the traffic volumes and service levels, Alternative 4 

cannot meet the required criteria of sufficient land identified 

in the Purpose and Need for the project. Therefore, 

Alternative 4 is not viable and has been eliminated from 

further consideration. 

2.3.1.4 Alternative 5: IMF on Pictsweet Property 

Alternative 5 (approximately 884-acre site) would include 

constructing an IMF along the north side of the mainline 

tracks west of Rossville on the Pictsweet Property (Figure 

2-6). This alternative would be located between the NSR 

mainline and the Wolf River. Although this location has 

adequate acreage, site development is constrained by the 

Wolf River floodway and floodplain. The majority of the 

facility would be located within the floodplain and grading 

work would require considerable site preparation and filling 

costs. Environmental considerations include impacts to 

several streams and wetlands. In addition, the U.S. 

Environmental Protection Agency (EPA), in agreement with 

other cooperating agencies, would need to remove a deed 

restriction on approximately 20 acres of land in a 65 acre 

restricted area on the west-side of the site to build the 

IMF.44 This restriction was put in place as part of a 1993 

Consent Order due to unauthorized construction in the 

area.45 Avoiding these restricted acres would require a 

smaller, less efficient facility. Construction of Alternative 5 

would also increase traffic on SR-57 for about three miles 

prior to its connection with SR-385 to the west. SR-57 is a 

two-lane road which is considered a rural minor arterial. 

The access road would require construction of an overpass 

over the NSR mainline track to access to the site. 

While Alternative 5 is a viable alternative, meeting the first 

four criteria identified in the Purpose and Need for the 

 

44 Fayette County, TN, Fayette County Register, “Deed Book 389, page 79, Exhibit 5,” 1993. 

45 EPA, “Docket No. 404-90-08,” Signed December 8, 1993. 
2 ALTERNATIVES

Memphis Regional Intermodal Facility 2-13

6/30/2010 

project, the cost of developing this site, as well as the 

potential natural resources impacts, the potential difficulty 

of environmental permitting, and potential land use 

restrictions in comparison to Alternative 1, resulted in 

Alternative 5 being eliminated from further consideration. 

2.3.1.5 Alternative 6: Intermodal Gateway at Memphis 

Pidgeon Park 

Alternative 6 would require expansion of the Intermodal 

Gateway at Memphis in Pidgeon Park on the Canadian 

National Railway (CN) southwest of Memphis (Figure 2-5). 

Sufficient land is available for the development; however, 

to gain rail access, an expensive rail connection to the CN 

would be required. This would require that a deep trench 

be constructed from below the west end of Forrest Yard to 

the CN track. This trench would further reduce the 

capability of the Forrest rail yard. More importantly, the 12 

to 13-mile CN route from Forrest Yard to Pidgeon Park 

passes through the busiest section of the CN Memphis 

terminal. Without extra route investments on the CN line 

beyond the above-mentioned connection, this route is 

incapable of handling the additional NSR trains in a timely 

manner. Without consistent train performance and truck 

competitive train schedules, Alternative 6 could not serve 

the projected demand for freight transportation, thus 

negating the purpose. This location would add 

approximately 39 additional rail miles for traffic to and from 

Memphis relative to the Fayette County sites. This 

alternative would also add extra operating costs. With the 

area’s industrial development moving east and south of 

Memphis, the Pidgeon Park Alternative southwest of 

Memphis would increase drayage miles. Drayage is the 

cost associated with a vehicle hauling an item. These 

additional drayage miles would increase drayage costs. 

Route deficiencies requiring exorbitant investment and 

extra rail transit time, operating cost issues and the fact 

that this alternative is unable to meet the required criteria 

of proximity to NSR rail infrastructure identified in the 

Purpose and Need for the project makes Alternative 6 a 

non-viable alternative. Alternative 6 has been eliminated 

from further consideration. 

2.3.2 Build Alternative 

2.3.2.1 Refinement of Alternative 

Build Alternative 1 was developed in a manner that took 

into account engineering, social, and environmental 

considerations. A Local government briefing and a public 

meeting were held in 2009 to gather input on the project’s 
 2 ALTERNATIVES

purpose and need. Previously studied alternatives were 

presented, including all of the alternatives described 

above. During these meetings, participants had the 

opportunity to discuss project needs and provide 

suggestions for possible alignments on a map of the study 

area. 

It is recommended that this alternative, along with the NoBuild Alternative, be carried forward in the NEPA process. 

2.3.2.2 Description of Build Alternative 

Build Alternative 1 would consist of constructing and 

operating a new Memphis Regional IMF in southern 

Fayette County, Tennessee, approximately 25 miles east 

of Memphis. It would be designed to handle trailers and 

containerized freight. The IMF would be located 

approximately 1.5 miles south of SR-57 and 0.5 mile 

west of Knox Road in the city of Rossville (Figure 2-7). 

The facility would occupy about 380 acres on a 650-acre 

parcel of land. 

The property would include an approximately 1.6-mile 

long, 200 to 350-foot wide right-of-way for connection 

(lead) tracks between the facility and the NSR mainline. 

The facility would include a loop track at the south end of 

the facility for trains to reverse direction to return to the 

mainline. 

It would also include right-of-way (ROW) approximately 

2,000-feet long by 400-feet wide along SR-57 to 

construct a highway overpass across the connection 

tracks. The overpass establishes a grade separation with 

SR-57. 

Access to the IMF would be available from an 

approximately two mile-long, two-lane road southwest of 

the project area (referenced herein as “Industrial Road”), 

Figure 2-7. The road lanes and shoulder widths would be 

12-feet wide. The Industrial Road is being designed and 

built by a private developer (‘Developer’) is engaged in 

designing and building Industrial Road. This road, which 

would run between the project area and US Hwy 72 in 

Mississippi, would not only provide vehicle and truck 

access to the Memphis Regional IMF from US Hwy 72, but 

facilitate industrial and commercial development in the 

immediate area of the road. Industrial Road is being 

developed with non-Federal funds. Industrial Road is a 

stand-alone utility. The direct, indirect and cumulative 

impacts of the Industrial Road are evaluated as part of this 

EA. 

Memphis Regional Intermodal Facility 2-14

6/30/2010 
 2 ALTERNATIVES

Figure 2-7: Build Alternative 1 

Memphis Regional Intermodal Facility 2-15

6/30/2010 
 2 ALTERNATIVES

Memphis Regional Intermodal Facility 2-16

6/30/2010 

Between the Tennessee–Mississippi State Line and 

Mississippi Highway (MS) 302, north of Mount Pleasant, 

Mississippi, there is an approximately 6-mile section of US 

Hwy 72 that is still a two-lane road. US Hwy 72 is fourlanes on both sides of this two-lane section. Industrial 

Road would initially connect to this two-lane section of US 

Hwy 72. Under the MDOT permit application process, the 

Developer may be required to construct a four-lane section 

of US Hwy 72 to facilitate tying Industrial Road into US 

Hwy 72. As funding and prioritization allows, US Hwy 72 

will be a four-lane highway for its length in Mississippi in 

accordance with MDOT Vision 21.46 

The stretch of US Hwy 72 in Tennessee, which connects to 

SR-385, Bill Morris Parkway, is already a four-lane 

highway. In addition, the TDOT is programming SR-385 to 

be four-lane from US Hwy 72 to Interstate 40.47 In Build 

Alternative 1, US Hwy 72 is used for truck access. Figure 

2-8 illustrates the above described roadway network. 

Community and governmental entities in this part of 

Fayette County, Tennessee, have expressed a desire for 

the facility to access US Hwy 72 instead of SR-57 due to 

the differences in their functional classification, design 

capacity, and long-range plans. Under Build Alternative 1, 

truck and employee vehicle traffic would enter and exit the 

IMF using the Industrial Road connecting to US Hwy 72. 

The Memphis Regional IMF would not be directly 

accessible from SR-57, except for limited access by 

emergency vehicles. The site for Build Alternative 1 was 

annexed and zoned by the Town of Rossville with the 

traffic access limited to US Hwy 72. 

As with any project of this magnitude, the conceptual 

planning phase is critical to meet the shared objectives of 

economic and operational feasibility as well as the 

accepted standards for human and environmental 

protection. This process is typically iterative and plans 

that are developed to meet engineering needs are 

simultaneously reviewed to balance any consequences of 

the proposed action on the environment or the public, 

including impacts from construction and operation. As the 

conceptual planning for the Memphis Regional IMF has 

proceeded, there have been several opportunities for the 

public, governmental agencies and Non-Governmental 

Organizations (NGO) to review and comment on the 

 

46 MDOT Planning Division, “Vision 21 map,” 2002 

http://www.gomdot.com/Divisions/IntermodalPlanning/Resources/Maps/pdf/Vision21.pdf. 

47 TDOT, “State Transportation Improvement Program,” October 2007 

http://www.tdot.state.tn.us/programdev/docs/STIP2008_2011.pdf. 
 2 ALTERNATIVES

Memphis Regional Intermodal Facility 2-17

proposed project. The following issues are of particular 

interest and have been specifically evaluated for potential 

adjustments to further avoid, minimize or mitigate impact: 

Wetlands and Streams, Sensitive Habitats, Stormwater 

Management and Water Quality, Aquifer, Traffic, Visual 

and Lights, Noise, and Energy. 

Figure 2-8: Roads around Build Alternative 1, Memphis Regional IMF

Part of Future I-269 

As part of the conceptual design process, several track 

alignments and facility adjustments are being evaluated 

and modified to balance engineering restrictions and 

6/30/2010 
 2 ALTERNATIVES

Memphis Regional Intermodal Facility \ 2-18 

6/30/2010 

resource conservation. Where possible, the design 

modifications avoided, and in all cases minimized 

impacts to natural resources while balancing engineering 

restrictions.48 Some changes in the alignment are often 

not practicable due to railroad and intermodal design 

requirements, for example, the need for straight and flat 

tracks of sufficient size to handle incoming train traffic 

and allow for efficient building of outgoing trains. The 

IMF would be designed to work as efficiently as possible 

within the smallest footprint possible. 

2.3.3 Comparison of Alternatives 

Table 2-2 summarizes the assessment of each alternative 

as evaluated against the previously described screening 

criteria. 

 

48 Norfolk Southern’s Standard Specifications for Materials and Construction. 
 

Memphis Regional Intermodal Facility \ 6/30/2010 

Table 2-2: Summary of Alternatives 

Considerations 

Build Alternative 

(Alternative 1) 

Memphis Region IMF 

Alternative 2 

East Rossville 

(Windyke Property) 

Alternative 3 

Expanded Forrest 

IMF 

Alternative 4 

Vulcan Property 

Alternative 

Pictsweet Pro

1* – Sufficient Land 

Yes. Yes. No - impractical to 

assemble a suitable amount of land. 

No - requires difficult or impossible relocation of existing and planned businesses. 

Yes - but EPA deed restriction on area nfor track connectionmainline must be reto avoid shortening beyond a reasonabnecessary level. 

2* – Proximity to NSR Rail Infrastructure 

Yes - within 2 miles of NSR mainline. 

Yes - adjacent to NSR mainline. 

Yes - adjacent to NSR mainline. 

Yes - adjacent to NSR mainline. 

Yes - adjacent to Nmainline. 

3* – Proximity to Highway Infrastructure 

Yes - US Hwy 72 (Rural Principle Arterial), combination 2- and 4-lane sections (programmed for 4) 

Yes - but SR-57 (Rural Minor Arterial), 2-lane road. 

Yes - urban collector to SR-277.

Yes - but SR-57 (Rural Minor Arterial), 2-lane road. 

Yes - but SR-57 (RMinor Arterial), 2-laroad. 

4* – Location 

Yes. Yes. Yes. Yes. Yes. 

5 – Impact to Natural Resources 

Moderate impacts to natural resources: 

 Affect ~ 3 to 8 acres of 

wetlands. 

 Impact ~ 5,000 linear 

feet of stream. 

 Potential impact to Zone 

A within unnamed tributary to Wolf River floodplain. 

 Attainment for air quality 

Potential serious impacts to natural resources: 

 Affect ~ 4 to 6 acres of 

wetlands. 

 Impact ~ 5,000 linear 

feet of stream. 

 Portions of lead tracks 

to IMF would be within Wolf River floodplain. 

 Potential run-off to 

Exceptional Tennessee Water (ETW). 

 Attainment for air quality 

Low impact to natural resources as site is within an urban area. 

 Non-Attainment for 

air quality 

Moderate impacts to natural resources: 

 Affect ~ 10-15 acres of 

wetlands. 

 Impact ~ 1,500 linear 

feet of stream. 

 Connections to NSR 

mainline within Wolf River floodplain. 

 Attainment for air 

quality 

Potential serious imto natural resources

 EPA consent orde

restricted land witproject footprint. 

 Affect ~ 15 acres 

wetlands. 

 Impact ~ 1,500 lin

of stream with sprsite. 

 Site within Wolf R

floodplain. 

 Attainment for air 

6 – Impact to Cultural, Historical, and Social Resources 

 No eligible or listed 

archaeological sites within project boundary. 

 No disproportionate or 

adverse effect to minority or low-income populations 

 Potential adverse effect 

on a 1.2-acre Civil War earthwork. 

 Nearby minority 

population on Mt. Pleasant Road. 

 No previously 

identified archaeological sites within project boundary. 

 Nearby minority 

populations. 

 No previously identified 

archaeological sites within project boundary. 

 Nearby low-income 

population on Morrison Road. 

 No previously ide

archaeological sites project boundary. 

 Nearby adverse 

on low-income popon Morrison Road. 

* Denotes criterion that must be clearly met for an alternative to be considered viable.
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

2.4 Identification of Build Alternative 

Based upon the information to date and the assessments 

above, NSR preferred Alternative 1 and TDOT and FRA 

concurred that only Build Alternative 1 is a reasonable 

based on the following considerations: 

 Sufficient land is available to develop the facility, 

meet intermodal demand, and support the 

infrastructure, operations, and storage 

requirements. The rectangular 650-acre property 

has adequate width and length for facility layout 

and provides suitable land for effective intermodal 

operations. 

 The site is located a reasonable distance 

(approximately 2 miles) from the NSR mainline and 

can be accessed via connection (lead) tracks under 

SR-57. 

 The proposed site is located near adequate highway 

infrastructure with connection to US Hwy 72 

provided by Industrial Road. From US Hwy 72, the 

Memphis Regional IMF truck traffic would have 

connectivity to a four-lane road, SR-385. Both of 

these roads have available capacity and would allow 

trucks to make easy trips between the facility and 

customers throughout the Memphis metropolitan 

area. 

 The facility’s customer base is generally moving 

eastward and southward in the Memphis 

metropolitan area. Locating the Memphis Regional 

IMF east of Memphis matches the region’s industrial 

and commercial area for economic activity. 

 While some impacts are expected to streams and 

wetlands on the property, these impacts would be 

avoided, minimized, or mitigated. 

 Build Alternative 1 would have no impacts on 

cultural or historical resources that are listed or 

eligible for listing on the National Register of Historic 

Places (NRHP). 

 

 

Memphis Regional Intermodal Facility 3-1

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-2

6/30/2010 

3 ENVIRONMENTAL CONSEQUENCES OF 

THE PROPOSED ACTION 

This chapter focuses on the potential impacts to the natural 

and human environment due to Build Alternative 1. Build 

Alternative 1 would be located approximately 1.5 miles 

south of SR-57 and 0.5 mile west of Knox Road in the 

City of Rossville, Tennessee. 

NEPA requires that Federal agencies incorporate 

environmental considerations in their planning and 

decision-making process. In order to understand the 

project area and sufficiently evaluate the potential for 

environmental impacts associated with constructing and 

operating the Memphis Regional IMF, the following studies 

were conducted: 

 Air Quality Technical Report, 

 Archaeological Survey, 

 Architectural and Historic Survey, 

 Ecology Report, 

 Geotechnical Investigations, 

 Hazardous Materials Report, 

 Noise Analysis Technical Report, 

 Traffic Impact Study, 

 Traffic Impact Study – Intersection SR-57 

and Neville Road, and 

 Analysis of Projected Traffic and Impacts - 

Vicinity of Intersection of US Highway 72 

and Industrial Road. 

This environmental document identifies which aspects of 

the proposed action have potential for social, economic, or 

environmental impact based upon the studies listed above, 

an assessment of resources, and input from the public, 

governmental agencies, NGO, and other sources.49 This 

chapter identifies the existing conditions for each resource 

area and details potential environmental impacts of Build 

Alternative 1. Before discussing Build Alternative 1; it is 

worth noting that the No-Build Alternative would not disturb 

the project site nor result in any of the immediate impacts 

 

49 23 C.F.R. 771. 
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that the Build Alternative would generate. However, the 

No-Build Alternative would not generate the many benefits 

that Build Alternative 1 would generate or fit the Purpose 

and Need for the project. 

This section also identifies Local, State, and Federal 

requirements applicable to the project. 

3.1. Land Use 

3.1.1 Existing Land Uses 

The proposed Memphis Regional IMF and SR-57 overpass

would be located southeast of Memphis near Rossville in 

Fayette County, Tennessee (Figure 2-7). Industrial Road 

is located in southwestern Fayette County, Tennessee, 

and northern Marshall County, Mississippi. Somerville is 

the Fayette County seat and Holly Spring is the Marshall 

County seat. 

The majority of Fayette and Marshall Counties are rural in 

nature. Fayette County is home to ten towns and 

municipalities. The project area (including lead tracks, 

loop track, facility and SR-57 overpass) is located between 

the towns of Piperton and Rossville. The site lies within 

the Rossville UGB.50 Industrial Road would be located 

within the rural area of the Fayette County Growth Plan 

and an un-designated area of Marshall County. Although 

the counties are predominantly agricultural, they are 

expected to continue to grow in population and 

commercial/industrial development. 

In April 2010, Marshall County changed the zoning of the 

property along Industrial Road and directly across US Hwy 

72 from Industrial Road from A-R (Agricultural-Residential) 

and R-E (Residential-Estate) to C-2 (Commercial) and I-1 

(Industrial).51

Current Fayette County property attributes are depicted in 

Figure 3-1.52 Build Alternative 1 would be located in an 

area attributed as industrial (IH) use. The adjacent land 

uses are rural residential, which includes single, duplex, 

and manufactured/trailer residences (R1 and R2 with the 

only difference being that R2 includes complying with a 

grass ordinance). 

 

50 Fayette County Growth Plan Map, August 2003, http://www.fayettetn.us/FC%20Growth%20Plan%202.htm. 

51 Marshall County Planning Commission, April 8, 2010 Planning Commission Meeting Minutes.

52 Property Attribute map created October 2009 by Fayette County Planning and Development Office. 
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Figure 3-1: Property Attributes for Fayette County 

Figure 3-2 shows proposed zoning and annexations for the 

Town of Rossville.53 It shows that the project site was part 

of the re-zoning and annexation presented in June 2009. 

The project site is shown within its own Industrial 

Development Overlay District. The District is designated 

M-1, general industrial, which would allow a broad range of 

industrial uses geared towards warehouse distribution, 

light manufacturing, an IMF with access limited to US Hwy 

72, and limited retail sales and services. The land 

bordering the project site within the Town of Rossville was 

re-zoned in 2009 to include currently undeveloped medium 

and high density residential zoning.54 The Rossville 

Planning and Zoning Board is currently updating their 

 

53 Town of Rossville Planning and Zoning, 2009. 

54 Town of Rossville Planning and Zoning, 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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zoning map to reflect the recently approved zoning 

revisions.55

Figure 3-2: Town of Rossville Proposed Zoning Annexations Map 

Most of the land within the project boundary was previously 

disturbed over the last century primarily for agricultural 

purposes and some tree clearing. It currently consists of 

both forested (mixed hardwood) and non-forested (hay 

fields) areas. The property was purchased in 2007 by a 

private developer with plans to develop the property for 

investment purposes.56 The site consists of rolling hills 

and varies in elevation from approximately 310-450 feet 

above mean sea level (amsl).

 

55 On 21 Jun 2010, Esther Sykes Woods, Fayette County Planning and Development, confirmed that there were not any 

changes from the proposed rezoning figure to the final rezoning figure.

56 TN Comptroller of the Treasury, Real Estate Assessment Data, 

http://www.assessment.state.tn.us/SelectCounty.asp?map=true&SelectCounty=. 
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As noted in Section 1.5, warehouse square footage 

development since 2002 has increased in the project 

vicinity (Figure 1-9) and industrial development is 

anticipated to increase south and east of Memphis, 

sprawling from the city to the project vicinity.57 This 

growth in warehouse and industrial development is due to 

a number of factors including proximity to highway 

infrastructure, developable land, and the Memphis area’s 

role in transportation, shipping and freight.

3.1.2 Land Use Impacts 

Fayette County completed its 20-year regional land use 

growth plan in August 2003 (2003 Fayette County Growth 

Plan). The plan identifies the project site as part of the 

Rossville UGB. An urban growth area is a regional 

boundary, set in an attempt to control urban sprawl by 

encouraging the area inside the boundary be used for 

higher density urban development and the area outside be 

used for lower density development. Rossville is in the 

process of developing a comprehensive land use plan. 

Two of the land use goals and objectives of the Fayette 

County Growth Plan are to: 

 Encourage a pattern of compact and contiguous 

high density development to be guided into urban 

areas or planned growth areas and 

 Promote the adequate provision of employment 

opportunities and the economic health of the 

region.58

The Fayette County Growth Plan identifies areas where 

the Town of Rossville believes it can supply water, sewer 

and other infrastructure within the next 20 years. The 

Memphis Regional IMF development is consistent with 

both of these Fayette County Growth Plan goals and 

objectives. 

Fayette County contains an estimated 227,434 acres used 

for agricultural purposes (approximately 50% of the 

county). Approximately 309 acres of the project property 

would be directly converted from agricultural use to 

commercial use by the Memphis Regional IMF. The 

project would directly impact approximately 164 acres of 

forested areas and 145 acres of pasture. Less than 0.2% 

of agricultural land in the county would be affected by the 

 

57 Greater Memphis Chamber of Commerce, “Map Gallery,” 

http://welcome.memphischamber.com/Economic-Development/Map-Gallery.aspx. 

58 Fayette County Tennessee, “The Formation of the: Growth Plan Coordination Committee of Fayette County,” 2004 

http://www.fayettetn.us/FC%20Growth%20Plan%202.htm. 
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project. Commercial uses include approximately 76 acres 

for the lead tracks; 232 acres for concrete pavement for 

buildings, onsite roads, and trailer parking; and 1 acre for 

pervious pavement for employee parking areas. 

Marshall County contains an estimated 364,175 acres 

used for agricultural purposes (approximately 82% of the 

county). Industrial Road would affect approximately 11.1 

acres of agricultural land in Marshall County (less than 

0.003% of total agricultural land in Marshall County). 

Industrial Road would directly convert approximately 10 

acres of pasture and 1.1 acres of forested areas to paved 

roadway. 

Land use surrounding the project area is presently 

categorized as agricultural, forested, and rural residential 

(Photos 3-1 and 3-2). Over 70% of the immediately 

surrounding area consists of agricultural and pasture 

lands.59 Forested areas, which cover less than 30% of the 

surrounding area, are sporadic and primarily occur along 

drainages.60 Residential development is relatively sparse; 

approximately 55 residences are located within 1/2 mile of 

the project area. At one time, the project site was part of a 

larger ranch known as Twin Hill Ranch.61 Cattle and 

horses were raised on the ranch. While the ranch was 

active, four lakes were created on the property including 

Big Lake southwest of the IMF footprint. 

Land use is changing primarily along the existing main 

roadways. Commercial and residential developments exist 

along SR-57 in the project area with new residential areas 

occurring or expanding along SR-57 between Rossville 

and Collierville. In Mississippi, commercial development is 

expanding along US Hwy 72. An example is the 

Chickasaw Trail Industrial Park, which is at the intersection 

of Cayce Road and US Hwy 72. The Chickasaw Trail 

Industrial Park (Photo 3-3) (a Marshall County supported 

development) is located along and southwest of Industrial 

Road. Commercial and residential development is planned 

for the areas south of the project site along Industrial Road 

and along the southern side of US Hwy 72. 

The project area shows signs of transition from a primarily 

rural residential and agricultural area to a mixture of urban 

and industrial areas. The Memphis Regional IMF is part of 

this transition. 

 

59 Visual estimates based on 2009 Imagery from Google Maps. 

60 Visual estimates based on 2009 Imagery from Google Maps. Supported by FWS, November 2007, Forest Inventory & 

Analysis Factsheet Tennessee 2004. 

61 Mid-South Horse Review, “How Green Was Long Green Valley: A Tribute to Twin Hill Ranch,” 2009 (Somerville, TN: 

Mid-South Horse Review). 
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As noted in Section 3.1.1, even without the Memphis 

Regional IMF, the area has experienced growth in 

warehouse square footage and industrial development 

south and east of Memphis. The increase and growth is 

due to a number of factors including infrastructure and 

long-standing regional development trends. Build 

Alternative 1 is consistent with these trends and would 

therefore not have substantial impact on land use in the 

area. The Town of Rossville re-zoned the area around the 

proposed location as an Industrial Development Overlay 

District in 2009. The intermodal facility has a zoning 

designation of M-1, which allows placement of an IMF with 

access limited to US Hwy 72.62

No land use impacts are anticipated from the No-Build 

Alternative. The land would remain zoned for industrial 

use. 

3.2 Farmland Impacts 

Even though a large percentage of land in Fayette County 

is classified as agricultural, it is in a transitional period as 

suburban growth spreads from Memphis. The 2003 

Fayette County Growth Plan in Figure 3-3 shows the 

project boundary within Rossville’s UGB. 

Industrial Road is partially located in the designated rural 

section of the Fayette County Growth Plan and partially in 

a rural section of Marshall County, Mississippi. Marshall 

County does not have a growth plan. Marshall County 

recently changed the zoning of the property along 

Industrial Road and directly across US Hwy 72 to Highway 

Commercial District and Light Industrial and accordingly 

these properties are no longer contemplated to result in 

future farm use. 

The Memphis Regional IMF, including the SR-57 overpass, 

would encompass approximately 590 acres with 309 acres 

being directly converted and 281 acres being indirectly 

converted from farmland. Land would be directly 

converted from farmland in areas of facility buildings, 

tracks, container and trailer storage areas, and paved 

areas or roads. Land would be considered indirectly 

converted if it would no longer be capable of being farmed 

 

62 In recognition of the importance of rail transportation in interstate commerce, Congress has enacted legislation 

providing that federally regulated railroads operating in interstate commerce are not subject to otherwise applicable local 

and state laws. See Interstate Commerce Commission Termination Act of 1995 ("ICCTA"), 49 U.S.C.§ 10501 and the 

Federal Railway Safety Act of 1970 ("FRSA"), 49 U.S.C. § 20101 et seq. In accordance with these and other similar 

federal laws, most state and local regulation of railroads is preempted in order to ensure barriers to interstate commerce 

are not created. This includes local planning, zoning and similar laws and ordinances. However, for this project, zoning 

regulations and authorizations, to the extent applicable to rail, have been complied with and obtained.
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for the duration of the existence of the facility because 

access would be restricted. Based on the Natural 

Resources Conservation Service (NRCS) completed 

Farmland Form, approximately 311 acres of farmland 

within the project site is rated as prime and unique.63

3.2.1 Existing Farmland Uses 

In 2002 in Fayette County, Tennessee, 273,817 acres of 

land were in farms (approximately 61% of Fayette County’s 

451,839 acres). Farmland acreage decreased over the 

next five years to 227,434 acres (approximately 50%).64 

The Fayette County Cooperative Extension Service 

anticipates that the 2010 census would identify a continued 

decrease in the farmland acreage as farmland is converted 

to residential, commercial and industrial use.65 

Figure 3-3: Project Area on Fayette County Growth Plan 

In 2009, farmland in Marshall County, Mississippi, included 

364,175 acres (approximately 82% of Marshall County’s 

443,520 acres).66 Based on information from the Marshall 

 

63 NRCS Letter Dated 16 October 2009 from Charles L Davis, Resource Soil Scientist. 

64 USDA, “2007 Census of Agriculture,” December 2009. 

65 Personal communication with Fayette County Cooperative Extension Service, October 2009. 

66 Personal communication with Marshall County Cooperative Extension Service, October 2009. 

Project 

Boundary 
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County Industrial Development Authority, the amount of 

farmland in the county over the last 10 years has only had 

a slight decrease due to conversion of farmland to 

residential, commercial and industrial use.67 

3.2.2 Farmland Impacts 

In accordance with Farmland Protection Policy Act (FPPA) 

regulations68, soil and site assessment criteria were 

applied to determine effects to farmland. The site 

assessment criteria are designed to assess important 

factors other than the agricultural value of the land to 

protect farmland. 

Each factor is assigned a score relative to its importance 

on a Farmland Conversion Impact Rating Form (AD-1006). 

Sites that receive a total site assessment score of 160 

points or less are given a minimal level of consideration for 

protection. Sites with a total site assessment score of 160 

points or more require the consideration of alternative 

project alignments that would still serve the proposed 

purpose but would convert either fewer acres of farmland 

or otherwise impact farmland that has a relative lower 

value. 

With assistance from the NRCS, it was determined that 

Build Alternative 1 including lead tracks, facilities, and SR57 overpass would have a site assessment score of 151 

points. Since the point total is below 160 points, an 

examination of additional alternatives is not necessary. 

The completed NRCS-AD-1006 Form is included in 

Appendix A 

Based on site information and coordination with the NRCS, 

the proposed project would not have a substantial impact 

to farmland. 

No farmland impacts are anticipated under the No-Build 

Alternative. Currently, the site is not being farmed except 

for hay cutting. The property is zoned for industrial use 

and is within the Rossville UGB. 

3.3 Transportation Impacts 

3.3.1 Freight Transportation 

Freight operations are the practical work of moving goods 

from a shipper to a receiver. In the U.S., the private sector 

is responsible for most freight operations. The public 

sector also has a role in freight operations through its 

 

67 Personal communication with Fayette County Cooperative Extension Service, October 2009. 

68 7 C.F.R. Part 658 
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ownership and management of the Nation’s highway 

system, ports, and inland waterways, and its regulation 

and taxation of freight movement.69 

Build Alternative 1 would combine rail and truck freight 

movements to improve transportation capacity in the 

Memphis region and provide an energy efficient alternative 

for current and future freight transportation. It would also 

improve operational efficiency, volume and speed of 

delivery.70 The additional capacity of Build Alternative 1 is 

required to meet growing freight demand as shown 

previously in Figure 1-2. The facility would annually handle 

an estimated 187,000 loaded trailers or containers moving 

between the Memphis Region and the Northeast in 

addition to freight moving in other, lower volume corridors. 

At this time, traffic along the NSR mainline in the Rossville 

area includes about 18 trains per 24 hour period (about 

nine trains each direction). About four of those trains (2 

each direction) are intermodal trains. When the Memphis 

Regional IMF becomes fully operational, NSR expects the 

new intermodal traffic to be approximately four westbound 

trains terminating and four eastbound trains originating 

each day (eight intermodal trains movements). Two of 

these intermodal train movements would have previously 

traveled to the Forrest IMF in Memphis. The net result 

would be an increase of a predicted 6-7 intermodal trains 

on the NSR mainline east of the proposed IMF and a 

reduction of 1-2 intermodal trains on the mainline west of 

the IMF each day. A typical NSR intermodal train length is 

8,000 feet. Trains would access the Memphis Regional 

IMF via a pair of tracks (lead tracks) extending between it 

and the NSR mainline. 

To minimize the impact on highway traffic from trains 

entering or exiting the facility via the lead tracks, a grade 

separation would be established at SR-57. The grade 

separation would route the highway over the lead tracks. 

With the proposed overpass, no long-term impact on SR57 is anticipated. Truckers and workers would access the 

Memphis Regional IMF from US Hwy 72, not SR-57. 

Several potential facility access routes were considered in 

the design, and as previously noted; access was one of 

the critical evaluation criteria for assessment of various 

locational alternatives. NSR has proposed to use a facility 

 

69 FHWA, “Freight Management and Operations, Key Freight Transportation Challenges, 

http://ops.fhwa.dot.gov/freight/publications/fhwa 3004/operate.htm. 

70 FHWA 2005. FHWA and federal agencies, including the USEPA promote the development of intermodal facilities and 

transportation to provide reduced energy consumption and air emissions. 

http://www.fhwa.dot.gov/environment/cmaqpgs/intermodal/index.htm. 
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entrance that would result in all vehicles entering and 

exiting the Memphis Regional IMF via Industrial Road and 

US Hwy 72 in Mississippi.71 The widening of US Hwy 72 

is scheduled to start in 2012. In order to minimize traffic 

impacts, NSR proposes that there would be no commercial 

access to the facility from SR-57 or Knox Road. 

Emergency vehicle access to the IMF would be from SR57. These proposals are based on traffic studies that have 

been completed in association with this project. 

3.3.2 Traffic Analysis 

Traffic on US Hwy 72 was analyzed at three different 

years. The first year was 2009 or the existing traffic 

conditions and level of service comparisons. The second 

year was 2015 or the horizon year. The third year was 

2032 or the 20-year projection. Year 2032 was the design 

year requested by Mississippi Department of 

Transportation (MDOT).72 

The 2009 November Traffic Impact Study (on file with 

TDOT and the MDOT) was performed to assess the 

potential traffic impacts due to the proposed Memphis 

Regional IMF on US 72 and its intersections with SR 196, 

Cayce Road, Red Banks Road, Knox Road and Industrial 

Road.73 The traffic analysis followed the MDOT Design 

Guidelines.74 Traffic volumes on US Hwy 72 in the vicinity 

of the project site have decreased at a rate of 

approximately 1% per year over the past 5 years.75 For 

the November 2009 Traffic Impact Study, the existing 

traffic volumes at the study intersections were increased by 

1% per year to represent current trends in background 

growth. The Traffic Impact Study concluded that 

acceptable Level of Service (LOS) would be anticipated 

under Build Alternative 1 along US Hwy 72 and Industrial 

Road. Since the entrance to the Memphis Regional IMF 

via Industrial Road and US Hwy 72 would exist in 

Mississippi and not in Tennessee, traffic analysis in this 

impact study was limited to impacts along US Hwy 72. 

In response to comments from the October 22, 2009, 

public meeting, a separate traffic impact analysis was 

conducted for the intersection of SR-57 and Neville 

Road.76 This analysis evaluated whether a left turn lane 

 

71 AECOM, “Memphis Intermodal Facility, Traffic Impact Study” November 2009 Revision, On file with TDOT and MDOT 

(Nashville, TN: AECOM). 

72 MDOT’s comments to September 2009 Draft Traffic Impact Report. 

73 AECOM, Traffic Impact Study, 2009. 

74 MDOT, “Roadway Design,” http://www.gomdot.com/Divisions/Highways/Resources.aspx?div=RoadwayDesign. 

75 November 2009 AECOM Traffic Study and AADT volumes from two TDOT and two MDOT count stations (referenced 

in Traffic Impact Study). 

76 AECOM, “Memphis Intermodal Facility, Traffic Impact Study-Neville Road” November 2009 (Nashville, TN: AECOM). 
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on SR-57 was warranted based on current traffic volumes. 

The peak hour volume counts at the intersection of SR-57 

and Neville Road indicate the northbound approach on 

Neville Road carries less than ten vehicles during the AM 

and PM peak hours. These volumes are well below the 

minor street approach threshold for traffic signal warrants. 

Therefore, a full signal warrant analysis was not 

conducted. The analysis also evaluated whether the 

intersection of Neville Road and SR-57 is within a safe 

sight distance of the overpass. A safe sight distance is the 

length of roadway visible to a driver which provides for 

sufficient lengths on the intersecting roadway to allow a 

driver to anticipate and avoid potential collisions. Based 

on the current traffic volumes, a westbound left turn lane is 

not warranted at the intersection of SR-57 and Neville 

Road. For the design speed of 55 mph, at least 610 feet of 

intersection sight distance for vehicles turning left from 

Neville Road onto SR-57 and 495 feet of stopping distance 

is required. The proposed profile provides approximately 

1150 feet of sight distance from the intersection to the 

crest of the bridge over the lead tracks. 

Based on the request of MDOT77, the May 2010 Analysis 

of Projected Traffic and Impacts in the Vicinity of the 

Intersection of US Highway 72 and Industrial Road (on file 

with TDOT and MDOT) was performed to assess the 

potential traffic impacts due to the proposed Memphis 

Regional IMF using the following parameters: 78 

 A 2.5% per year increase in existing traffic 

volumes to represent the background traffic 

along US Hwy 72 (instead of the 1% increase 

developed based on historical growth trends), 

 US Hwy 72 as four-lane rural principal arterial 

with a design speed of 70 mph (instead of the 65 

mph originally provided), and 

 LOS C being the acceptable level of service 

(instead of LOS D used for original analysis79). 

3.3.3 Traffic Impact Evaluation 

In the vicinity of the project site between SR-196 to MS302, US Hwy 72 is a two-lane roadway, traveling in a 

northwest-southeast direction. US Hwy 72 presently 

carries approximately 11,225 vehicles per day (vpd) near 

 

77 Conference call with TDOT, MDOT, TN FHWA, NSR Consultants on Monday, April 12, 2010. 

78 Phone call between AMEC and MDOT on April 13, 2010; MDOT ED (Kim Thurman) defined these parameters. 

79 Highway Capacity Manual (HCM) states “most design or planning efforts typically use service flow rates at LOS C or D 

to ensure an acceptable operating service for facility users.” Although HCM uses LOS D in most of their examples, it 

gives each jurisdiction the flexibility to determine what is the minimum acceptable LOS for their roadway network. 
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the proposed intersection with Industrial Road. The 

capacity at which congestion would become apparent on 

this roadway is 14,000 vpd. 

Turning Movement Counts (TMCs) were conducted at the 

intersections listed below. Figure 3-4 illustrates the 

location of the area roads. The results indicated that the 

peak hours of traffic on US Hwy 72 occur between 6:15 

and 7:15 AM and 4:30 and 5:30 PM. 

 US Hwy 72 and SR-196 

 US Hwy 72 and Cayce Road 

 US Hwy 72 and Red Banks Road 

 US Hwy 72 and Knox Road 

Figure 3-4: Road Network around Build Alternative 

Mount Pleasant
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3.3.3.1 Existing Conditions 

To determine how efficiently US Hwy 72 serves the 

existing traffic conditions, a LOS analysis was conducted. 

The LOS is a qualitative measure that is used to gauge the 

operational performance of an intersection. There are six 

levels ranging from “A” to “F” with “F” being the worst. 

Each level represents a range of operating conditions. 

Table 3-1 defines the traffic flow conditions and 

approximate driver comfort at each level of service. The 

2009 November Traffic Impact Study prepared for the 

Memphis Regional IMF, utilizes LOS D as the minimum 

acceptable level of service. Based on further guidance 

from MDOT, the minimal acceptable level of service for the 

analysis was changed to LOS C.80

Table 3-1: Level of Service (LOS) Index 

LOS Traffic Flow Conditions 

Delay (seconds) 

Signalized 

Intersections 

Delay (seconds) 

Unsignalized 

Intersections 

A Progression is extremely favorable 

and most vehicles do not stop at all. 0-10 0-10 

B Good progression, some delay. 10-20 10-15 

C Fair progression, higher delay. 20-35 15-25 

D Unfavorable progression, congestion 

becomes apparent. 35-55 25-35 

E Poor progression, substantial delay. 55-80 35-50 

F Poor progression, extreme delay. >80 >50 

As indicated in Table 3-2 under the existing traffic 

conditions (2009), the northbound approach of Red Banks 

Road at US Hwy 72 (approximately 1.6 miles east on US 

72 from the intersection of US 72 and the proposed 

Industrial Road) currently operates at LOS D during the 

PM peak hour. 

Under existing traffic conditions, the northbound approach 

of Red Banks Road at US Hwy 72 is operating at 

unacceptable levels of service. 

 

80 MDOT comments to Draft EA on March 19, 2010. 
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Table 3-2: Level of Service – Existing Conditions (2009) 

Intersection Control Movement 

LOS 

AM PM 

US 72 @ SR-196 2-way Stop 

EB Left Turn B A 

SB Left/Right Turn C C 

US 72 @ Cayce Road Signalized Overall Intersection B B 

US 72 @ Knox Road 2-way Stop 

EB Left Turn A A 

SB Left/Right Turn B C 

US 72 @ Red Banks Road 2-way Stop 

EB Left Turn A A 

WB Left Turn A A 

NB Left/Thru Right C D 

EB – Eastbound, SB – Southbound, WB – Westbound, NB – Northbound 

3.3.3.2 Background Conditions 

Traffic volumes on US Hwy 72 (Photo 3-4) are expected to 

change between 2009, 2015 (horizon year) and 2032 

(MDOT requested design year), even if the proposed 

development is not completed. Traffic volumes on US Hwy 

72 in the vicinity of the project site have decreased at a 

rate of approximately 1% per year over the past 5 years. 

Nevertheless, the existing traffic volumes at the study 

intersections were increased initially by 1% per year to 

simulate the background growth.81 The rate of increase 

was changed to 2.5% per year growth (as requested by 

MDOT).82 

Results of LOS analyses for background traffic volumes 

indicate that all the turning movements and signalized 

intersections are expected to operate at LOS C or better 

during both peak hours in 2015, except northbound 

movement at the intersection of US Hwy 72 and Red 

Banks Road. This intersection would operate between 

LOS D to LOS E during the PM peak hour depending on 

the rate of growth of background traffic along US Hwy 72. 

In 2032, four movements rated at LOS D or below. First is 

northbound movement at the intersection of US Hwy 72 

and Red Banks Road, which would operate between LOS 

D during AM peak hour and LOS E during PM Peak hour. 

Additionally, southbound movement at the intersection of 

US Hwy 72 and SR-196 would operate from a LOS C to 

LOS E at both AM and PM peak hour depending on the 

 

81 November 2009 AECOM Traffic Study and AADT volumes from two TDOT and two MDOT count stations (referenced 

in Report). 

82 During a phone call between AMEC and MDOT on April 13, 2010, MDOT said their normal planning growth rate for 

NEPA studies was 2.5% growth compounded annually. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

growth rate used. The other turning movements and 

signalized intersections are expected to operate at LOS C 

or better during both peak hours in 2032. 

Table 3-3 shows the level of service provided at the 

reviewed intersections based on the predicted traffic along 

US Hwy 72 without any traffic from the IMF. The first level 

of service column per analysis in Table 3-3 was based on 

a 1% per year background growth (utilized in the 

November 2009 Traffic Impact Study) with US Hwy 72 as a 

two-lane road. The second level of service column per 

analysis in Table 3-3 was based on a 2.5% per year 

background growth (utilized in the May 2010 Analysis of 

Projected Traffic completed at MDOT’s direction) with US 

Hwy 72 as a two-lane road in 2015 and a four-lane road in 

2032. 

Table 3-3: Level of Service – Background Conditions (2015 and 2032) 

Intersection Control Movement LOS (2015) LOS (2032) 

AM PM AM PM 

% Background Growth Rate (per year) 1 2.5 1 2.5 1 2.5 1 2.5

US 72 @ SR-196 2-way Stop 

EB Left Turn B B A A B B A A 

SB Left & Right 

Turn C C C C C E C E 

US 72 @ Cayce Rd Signalized Overall 

Intersection B B B B B B C B 

US 72 @ Knox Rd 2-way Stop 

EB Left Turn A A A A A B A A 

SB Left & Right 

Turn B C C C C C C B 

US 72 @ Red Banks 

Rd 2-way Stop 

EB Left Turn A A A A A B A A 

WB Left Turn A A A A A A B B 

NB Left/Thru 

Right C C D E D C E E 

NOTE: The LOS is shown as a range with: 

The first LOS column per analysis was determined using a 1% growth rate (based on historical 

growth in the area) to existing US Hwy 72 traffic with US Hwy 72 analyzed as a two-lane road. 

The second LOS column per analysis was determined using a 2.5% growth rate (based on MDOT’s 

direction) to existing US Hwy 72 traffic with US Hwy 72 analyzed as a two lanes in 2015 and as four 

lanes in 2032 (shaded columns). 

Under background traffic conditions, incorporating 

standard growth, the northbound approach of Red Banks 

Road at US Hwy 72 would operate at unacceptable levels 

of service in both 2015 and 2032. The southbound 

intersection of SR-196 at US Hwy 72 would operate at an 

unacceptable level of service in 2032 as a result of 

background conditions without the Memphis Regional IMF. 

Memphis Regional Intermodal Facility 3-17

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

3.3.3.3 Future Conditions 

Future traffic volumes were obtained by adding the 

assigned projected trip generation numbers, also called 

the site generated traffic numbers, with the background 

traffic volumes for the years 2015 and 2032 respectively. 

Trips generated by the proposed Memphis Regional IMF 

were developed based on an expected 327,000 annual lifts 

(transfers of containers/trailers between train and truck) in 

2015, as well as an anticipated 140 employees, 65% of 

whom would be shift workers. Table 3-4 shows the daily 

traffic and AM and PM trips generated by the proposed 

Memphis Regional IMF in 2015 and 2032. 

Table 3-4: Trips Generated Directly By IMF (2015 and 2032) 

Daily Traffic

AM Peak Hour PM Peak Hour 

Enter Exit Enter Exit 

2015 2032 2015 2032 2015 2032 2015 2032 2015 2032 

Trucks 1,668 1,974 53 63 53 63 46 55 46 55

Passenger 

Vehicles 278 334 31 37 40 48 4 5 4 5

Total 1,946 2,308 84 100 93 111 50 60 50 60

Projected trip generation for the proposed facility includes 

1,668 trucks and 278 vehicles per day in 2015. This 

includes 106 trucks and 71 passenger cars entering/exiting 

in the AM peak hour and 92 trucks and 8 passenger cars 

entering/exiting in the PM peak hour. In 2032, daily trips 

are expected to grow to 1,974 trucks and 334 passenger 

cars. Approximately 31% of the Daily Truck Traffic is 

“bobtails”. “Bobtails” are tractors not pulling trailers, 

containers or bare chassis. 

Table 3-5 shows the level of service provided at the 

reviewed intersections with the predicted traffic along US 

Hwy 72 including the predicted traffic from the IMF. As 

noted, the first level of service column per analysis in Table 

3-5 was based on a 1% per year background growth with 

US Hwy 72 as a two-lane road. The second level of 

service column per analysis in Table 3-5 was based on a 

2.5% per year background growth with US Hwy 72 as a 

two-lane road in 2015 and a four-lane road in 2032. For 

2015 under projected conditions, only two approaches 

would operate at LOS D, E, or F. The first is the 

northbound approach of Red Banks Road at US Hwy 72, 

which is also anticipated to operate at unacceptable level 

of service without predicted traffic from the IMF. The 

second is the left turns from Industrial Road at US Hwy 72. 

Memphis Regional Intermodal Facility 3-18

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

The other turning movements and signalized intersections 

are expected to operate at LOS C or better. For 2032 

under projected conditions, three approaches would 

operate at LOS D, E, or F. The first two are the same 

approaches as 2015. The third approach is southbound 

approach of SR-196 at US Hwy 72, which is also 

anticipated to operate at unacceptable level of service 

without predicted traffic from the IMF. The other turning 

movements and signalized intersections are expected to 

operate at LOS C or better under future conditions. 

Though not warranted by the projected traffic, if a signal 

was installed at the intersection of US Hwy 72 and 

Industrial Road, the level of service would be LOS B during 

the AM Peak and LOS A during the PM Peak in both 2015 

and 2032. 

Table 3-5: Level of Service – Future Conditions (2015 and 2032) 

Intersection Control Movement LOS (2015) LOS (2032) 

AM PM AM PM 

% Growth Rate (per year) 1 2.5 1 2.5 1 2.5 1 2.5 

US 72 @ SR-196 2-way 

Stop 

EB Left Turn B B A A B C A A 

SB Left & Right Turn C C C C C E C E 

US 72 @ Cayce 

Rd Signalized Overall Intersection B B B B C C C C 

US 72 @ Industrial 

Rd* 

2-way 

Stop 

EB Left Turn B B A A B C B B 

SB Left Turn** D E E F E C F E 

SB Right Turn C C B B C C B B 

US 72 @ Knox Rd 2-way 

Stop 

EB Left Turn A A A A A B A A 

SB Left & right Turn C C C C C C C B 

US 72 @ Red 

Banks Rd 

2-way 

Stop 

EB Left Turn A A A A A B A A 

WB Left Turn A A A A A A B B 

NB Left/Thru Right C D D E D C E E 

* US Hwy 72 with one eastbound left turn lane, one westbound right turn lane and Industrial road with 

separate southbound right and left turn lanes. 

** Though not warranted by the projected traffic, if a signal was installed, the level of service would be LOS B 

during the AM Peak and LOS A during the PM Peak in both 2015 and 2032. 

NOTE: The LOS is shown as a range with: 

The first LOS column per analysis was determined using a 1% growth rate (based on historical growth in 

the area) to existing US Hwy 72 traffic with US Hwy 72 analyzed as a two-lane road. 

The second LOS column per analysis was determined using a 2.5% growth rate (based on MDOT’s 

request) to existing US Hwy 72 traffic with US Hwy 72 analyzed as a two lanes in 2015 and as four lanes 

in 2032 (shaded columns).

Though the southbound left turning movements onto US 

Hwy 72 from Industrial Road are predicted to be LOS D to 

LOS F, the expected number of left turning vehicles during 

the peak hour is 18 vehicles or less. Therefore, the 

Memphis Regional Intermodal Facility 3-19

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-20

6/30/2010 

warrants necessary to justify a signal are not meet for this 

intersection. Though not warranted based on the 

predicted traffic volumes, if the intersection of US Hwy 72 

and Industrial Road were signalized, the overall 

intersection would be expected to operate at LOS B or 

better. 

A two-lane segment of US Hwy 72 is expected to operate 

at LOS D in 2032 with or without traffic generated by the 

Memphis Regional IMF. With the 2.5% background growth 

and the traffic generated by the Memphis Regional IMF, 

the two-lane section of US Hwy 72 is expected to operate 

at LOS D in 2015. As a four-lane facility (which is 

programmed to be constructed), US Hwy 72 would operate 

at LOS C or better in 2015 and 2032.

US Hwy 72 is expected to carry between 13,900 vpd and 

15,000 vpd depending on growth rate83 in 2015 near 

Industrial Road, including site generated traffic. From 

2015 to 2032 traffic volume is expected to increase 

between 16,500 vpd and 22,200 vpd depending on growth 

rate, including site generated traffic. Within the 2015 and 

2032 expected traffic volume, the IMF traffic is 14% of the 

total. Figure 3-5 shows the hourly distribution of truck trips 

expected to be generated by the facility in 2015 and 2032. 

 

 

83 The 13,900 vpd and 16,500 vpd based on 1% per year growth rate for existing (background) traffic on US Hwy 72. 

The 15,000 vpd and 22,200 vpd is based on 2.5% per year growth rate. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-21

Figure 3-5: Memphis Regional IMF Hourly Distribution of Trips on US Hwy 72 

Using the same predicted traffic volumes for the IMF traffic 

as shown in Figure 3-5, Figure 3-6 shows the hourly 

distribution of truck trips expected to be generated by the 

facility and projected traffic on US Hwy 72 near Industrial 

Road in 2015 and 2032. 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE 

Figure 3-6: Projected Traffic on US Highway 72 near Industrial Road 

Memphis Regional Intermodal Facility 6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-23 

6/30/2010 

As shown in Figure 3-7, in 2015 the existing two-lane 

configuration on US Hwy 72 would accommodate the 2015 

volume without apparent congestion. Figure 3-7 

represents the approximate 13,900 vpd that US Hwy 72 is 

expected to carry in 2015 with the 1% per year growth rate, 

including the projected trip generation for the proposed 

facility of 1,668 trucks and 278 passenger vehicles per 

day. 

Figure 3-7: 2015 Roadway Volumes Two-Lane Segment US Hwy 72 (1% Growth) 

As shown in Figure 3-8, in 2015 the existing two-lane 

configuration on US Hwy 72 would accommodate the 2015 

volume with some congestion with the 2.5% per year 

growth in existing traffic along US Hwy 72. The traffic 

projected to be generated directly from the IMF is the same 

volume in both Figures 3-7 and 3-8. Figure 3-8 represents 

the approximate 15,000 vpd that US Hwy 72 is expected to 

carry in 2015 with the 2.5% per year growth rate, including 

the projected trip generation for the proposed facility of 

1,668 trucks and 278 passenger vehicles per day. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-24 

6/30/2010 

Figure 3-8: 2015 Roadway Volumes Two-Lane Segment US Hwy 72 (2.5% Growth) 

Results of left turn lane warrant analyses for AM and PM 

2015 peak hour volumes indicate that traffic volumes at 

Industrial Road warrant an eastbound left turn lane during 

both peak hours. While traffic volumes do not warrant a 

right turn lane on US Hwy 72 at Industrial Road, a 

westbound deceleration lane is required to reduce the 

potential for rear-end collisions and maintain a higher freeflow rate on US Hwy 72. An acceleration lane for the 

southbound right turns is also required at Industrial Road 

to provide trucks an opportunity to merge in gaps without 

significantly impeding traffic on US Hwy 72 or increasing 

the potential for a collision. These project-required 

improvements would be made by the private Developer in 

conjunction with the MDOT Highway Occupancy Permit 

(HOP). 

As outlined in the Manual of Uniform Traffic Control 

Devices (MUTCD), a traffic signal should not be installed 

unless traffic volumes and intersection characteristics meet 

a set of warrants or requirements. The intersection of US 

Hwy 72 and Industrial Road was evaluated for each of the 

warrants, for 2015 and 2032. The warrant analysis 

assumes two exiting lanes from Industrial Road, an 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-25 

6/30/2010 

eastbound left turn lane on US Hwy 72, and a westbound 

right turn lane on US Hwy 72. The results of the analysis 

indicate that neither the projected 2015 nor the projected 

2032 traffic volumes satisfy the requirements of the signal 

warrants. 

As shown in Figure 3-9, for the proposed four-lane 

configuration, US Hwy 72 would accommodate the 2015 

volume without apparent congestion. Figure 3-9 

represents the approximate 15,000 vpd that US Hwy 72 is 

expected to carry in 2015 with the 2.5% per year growth 

rate, including the projected trip generation for the 

proposed facility of 1,668 trucks and 278 passenger 

vehicles per day. 

Figure 3-9: 2015 Roadway Volumes Four-Lane Segment US Hwy 72 (2.5% Growth) 

Figure 3-10 represents the approximate 22,200 vpd, 

including the projected trip generation for the proposed 

facility of 1,974 trucks and 334 passenger vehicles per day 

plus a 2.5% per year growth in existing traffic expected in 

2032. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-26 

6/30/2010 

Figure 3-10: 2032 Roadway Volumes on Four-Lane Segment US Hwy 72 

Access to the proposed project site would be provided by 

Industrial Road that would intersect US Hwy 72 from the 

north, near Lenderman Road. According to AASHTO “the 

available sight distance on a roadway should be 

sufficiently long to enable a vehicle traveling at or near the 

design speed to stop before reaching a stationary object in 

its path.”84 Based on the 70 mph design speed85, the 

intersection of US Hwy 72 (as a two-lane road) and 

Industrial Road should be designed to provide at least 

1,180 feet and 1,080 feet of sight distance when looking to 

the west and east, respectively. With the same design 

speed for US Hwy 72 as a four-lane road, the intersection 

should be designed to provide at least 1,540 feet and 

1,440 feet of sight distance when looking to the west and 

east, respectively. 

3.3.3.4 Recommendations 

The MDOT plans to widen US Hwy 72 from MS-302 to SR196 to a four-lane roadway in the near future. A firm time 

 

84 AASHTO’s A Policy on Geometric Design of Highways and Streets, 2004, 

85 MDOT specified design speed for US Hwy 72 at 70 mph during a phone call with AMEC on April 13, 2010. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-27 

6/30/2010 

line has not been established for this improvement, 

thought it is currently programmed to start construction in 

2012 with an expected completion time of 2015.86 

e intersection during the 

future widening of US Hwy 72. 

ction with the MDOT Highway 

Occupancy Permit (HOP). 

vehicles from Industrial Road onto US Hwy 72. 

ing 

movement on Industrial Road at US Hwy 72. 

n US Hwy 72 at 

the intersection Industrial Road. 

adequate sight 

distance to the west and east. 

Hwy 72 at the intersection with Industrial Road. 

 

In anticipation of the planned widening of US Hwy 72 to 

four lanes in the vicinity of the project area, MDOT has 

requested that the design and construction of the proposed 

intersection of Industrial Road and US Hwy 72 include 

widening US Hwy 72 to four-lanes, with stub-outs to the 

east and west.87 By incorporating the planned widening of 

US Hwy 72 into the design of the proposed intersection, 

MDOT could avoid impact to th

Based on the evaluation and analyses of existing and 

future conditions, traffic generated by the proposed 

Memphis Regional IMF is expected to have a minimal 

impact on the adjacent roadway network. In order to 

address the expected operational impacts of the Memphis 

Regional IMF and provide safe traffic operations, the 

following configurations were included in the Traffic Impact 

Study. Figure 3-11 illustrates the required configuration of 

US Hwy 72 as a four-lane rural principle arterial. These 

project-required improvements would be made by the 

private Developer in conjun

 One each turn lanes for right and left turning

 Channelize the southbound right turn

 Add an eastbound left turn lane o

 Locate the intersection of US Hwy 72 and 

Industrial Road to provide 

 Add acceleration and deceleration lanes on US

86 Mississippi DOT 2010-2013 STIP. 

87 Meeting with MDOT, NSR, AECOM, AMEC, and Developer in Batesville on October 22, 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-28 

6/30/2010 

Figure 3-11: Proposed Improvements to Four-Lane US Hwy 72 

3.3.3.5 Conclusion 

Traffic impacts on US Hwy 72 due to Build Alternative 1 

are expected to be minor until 2015. By 2015, congestion 

would become apparent and four-lanes would be 

warranted assuming the 2.5% per year growth in 

background traffic.88 Throughout this timeframe, trucks 

should not be lining the sides of US Hwy 72 or Industrial 

Road to get into the Memphis Regional IMF. The AGS 

would be designed to include 5 inbound and 5 outbound 

queuing lanes to handle the anticipated peak traffic flow 

into the facility where there should be no more than three 

trucks queued at one time. Also the entrance to the 

Memphis Regional IMF is approximately 4,000 feet from 

the property boundary (along Industrial Road). 

Rail access alternatives to the facility were also 

considered. Among the issues for consideration are grade 

crossings. The lead tracks of Build Alternative 1 must 

cross SR-57 in order for trains to access the facility. NSR 

proposed a crossing at the north end of the project near 

the NSR mainline to be a grade-separated crossing to 

ensure that local traffic is not interrupted by trains on the 

lead track. This would consist of construction of the SR-57 

overpass. 

 

88 Using the 1% per year growth rate, congestion was not apparent until 2032. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-29 

6/30/2010 

Under the No-Build Alternative, traffic on US Hwy 72 would 

continue to increase. Results of the 2015 LOS analysis for 

background traffic indicated that all the turning movements 

and signalized intersections are expected to operate at 

LOS D or better. Results of the 2032 LOS analysis for 

background traffic indicate that those same movements 

would operate above LOS E, showing a need for increased 

capacity. 

3.4. Social Impacts 

This section describes the existing social characteristics of 

the local community and its residents and evaluates 

potential impacts of the proposed Memphis Regional IMF. 

It examines the people, the community, and public and 

social services.89 Data have been collected from 

previously published documents issued by Federal, State, 

and Local agencies and from State and National 

databases (e.g., data collected by the U.S. Census 

Bureau). The analyses presented in this section follow the 

Tennessee Environmental Procedures Manual Guidelines 

for Preparing Environmental Documentation for Federally 

Funded and State Funded Transportation Projects (April 

2007).90

3.4.1 Existing Social Conditions 

The area surrounding the project is categorized as 

forested, rural, residential, and agricultural (pastured 

livestock or cultivated agriculture). Approximately 55 

residences and two churches are located within 0.5 mile of 

the project boundary including the SR-57 overpass. 

Another five residences are located within 0.25 mile of 

Industrial Road. The properties that surround the project 

area are generally bordered by Neville Road and Parnell 

Road to the west, the railroad line north of SR-57 to the 

north, Knox Road to the east and the Tennessee/ 

Mississippi State Line to the south. 

Table 3-6 outlines general population data from the 1990 

and 2000 U.S. Census for Fayette County, Tennessee and 

Marshall County, Mississippi. Statewide information for 

both Tennessee and Mississippi is also included as a point 

of comparison. 

Table 3-6 illustrates that population growth for Fayette 

County is projected to be slightly less than the rest of 

Tennessee in 2000. Between 1990 and 2000, Tennessee 

 

89 FHWA, “Community Impact Assessment: A Quick Reference for Transportation” (Publication No. FHWA-PD-96-036), 

September 1996.

90 TDOT, Tennessee Environmental Procedures Manual: Guidelines for Preparing Environmental Documentation for 

Federally Funded and State Funded Transportation Projects, April 2007. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-30 

6/30/2010 

experienced a 14.0% increase in total population 

compared to 11.3% increase for Fayette County. 

However, the forecasted growth for Fayette County is 

25.8% by the year 2010 and 46.7% by 2020. Tennessee 

as a whole is forecasted to grow at a slower rate, with a 

projected growth of 8.7% by the year 2010 and 17.1% by 

2020.91

Table 3-6: Population Data 

Geographical 

Area 

1990 

Population 

2000 

Population 

Percent 

Change 

from 

1990 

Estimated 

2010 

Population 

Percent 

Change 

from 

2000 

Estimated 

2020 

Population 

Percent 

Change 

from 

2000 

Tennessee 4,890,525 5,689,283 14.0 6,229,564 8.7 6,860,231 17.1 

Fayette 

County, TN 25,559 28,806 11.3 38,848 25.8 54,051 46.7 

Mississippi 2,573,216 2,844,658 9.5 

3,090,895 

(Year 

2015) 

8.0 3,160,850 10.0 

Marshall 

County, MS 30,361 34,993 13.2 

37,691 

(Year 

2015) 

7.1 38,390 8.8 

Source: US Census Bureau, 2000, 2005 

Tennessee Advisory Commission on Intergovernmental Relations and The University of Tennessee Center for 

Business and Economic Research, June 2009 

The population growth for Marshall County and Mississippi 

are similar. Marshall County experienced a 13.2% 

increase in total population between 1990 and 2000, 

compared to a 9.5% increase for Mississippi. The forecast 

growth for Marshall County is 7.1% by the year 2015, and 

8.8% by 2020. Mississippi as a whole is forecasted to 

grow at a slightly faster rate, with a projected growth of 

8.0% by 2015, and 10% by 2020.92 

Table 3-7 contains demographic data for the project area 

based on the 2000 U.S. Census. As shown, minority 

populations comprise 19.9% of the population in 

Tennessee and 37.5% in Fayette County. The project 

area lies within Census Tract 607 and Block Group 3. 

Minority populations comprise 38.1% of Census Tract 607 

and 44.6% of Block Group 3. The percentage of minority 

populations within Block Group 3 is larger than the 

percentage in Fayette County and the State of Tennessee. 

Rossville has a 28.1% (105 individuals) minority 

populations; Piperton is at 14% (81 individuals); and 

 

91 US Census Bureau, 2000, 2005; Tennessee Advisory Commission on Intergovernmental Relations and The University 

of Tennessee Center for Business and Economic Research, June 2009

92 US Census Bureau, 2000/2005. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-31 

6/30/2010 

Collierville has an 11.2% minority populations (3,710 

individuals). 

According to the 2000 Census, minority populations 

comprise 39.3% of the population in Mississippi and 52.3% 

in Marshall County. The project area lies within Census 

Tract 9501 and Block Group 3. Minority populations 

comprise 39.1% of Census Tract 9501 and 26% of Block 

Group 3. In Byhalia, Mississippi, approximately 39% of the 

population is minority. The percentage of minority 

populations within Block Group 3 is lower than the 

percentage in Marshall County and the State of 

Mississippi. 

In Tennessee, the percentage of persons under 18 years 

of age in Block Group 3 is nearly equal to that of the State, 

County, and Census Tract (Table 3-7). Tennessee has 

approximately 24.6% of the total population under 18 years 

of age, and Fayette County has 25.7% of its residents 

being younger than 18. Block Group 3 has a slightly lower 

percentage of population under the age of 18 (22.9%) than 

Census Tract 607 (24.6%). 

In Mississippi, the percentage of persons under 18 years of 

age is 27.3% (Table 3-7). For Marshall County and 

Census Tract 9501, the percentages are similar, 26.6% 

and 26.4% respectively for population under 18 years of 

age. In Block Group 3, the percentage of persons under 

18 almost doubled in 49% 

FHWA defines "low-income" as a person whose household 

income (or in the case of a community or group, whose 

median household income) is at or below the U.S. 

Department of Health and Human Services poverty 

guidelines.* According to the 2000 Census, in 

Tennessee, Fayette County (14.3%), Census Tract 607 

(13.9%), and Block Group 3 (11.8%) have lower 

populations with incomes below the poverty threshold than 

in Mississippi (Table 3-7). Marshall County, Mississippi 

(21.9%) and Census Tract 9501 (16.9%) have slightly 

higher populations below the poverty threshold. This topic 

is discussed further in the Environmental Justice section 

(Section 3.4.2).93 According to the 2000 Census, Fayette 

County, Tennessee, Census Tract 607, and Block Group 3 

and Marshall County, Mississippi, Census Tract 9501 do 

not meet the definition of a poverty area as all areas are 

well below the 20% threshold (Table 3-7). This topic is 

discussed further in the Environmental Justice section 

 

93 See also FHWA, An Overview of Transportation and Environmental Justice, May 2000. 

http://www.fhwa.dot.gov/environment/ej2000.htm. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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6/30/2010 

(Section 3.4.2). Marshall County, Mississippi, however, 

does meet the definition of a “poverty area” because 

21.9% of its residents have incomes below the poverty 

threshold. 

3.4.2 Environmental Justice 

This project has been developed in accordance with 

Executive Order (EO) 12898 and Federal Actions to 

Address Environmental Justice in Minority and LowIncome Populations (1994), which requires identifying and 

mitigating disproportionately high and adverse impacts on 

minority and low-income populations with respect to 

human health and the environment.94 

To assess the impacts of Build Alternative 1 on minority 

and low-income populations, project planners reviewed 

U.S. Census data for the project area, coordinated with 

local government, and conducted a field review in 2009.95 

Based on the information gathered, it has been determined 

that this project would not have a disproportionately high 

and/or adverse effect on low-income or minority 

populations. 

At this time, no adverse impacts to a minority or lowincome population have been identified as a result of Build 

Alternative 1. Since the project avoids community 

segmentation and relocations, no adverse impacts are 

anticipated on local communities and the effects of the 

 

94 FHWA, “FHWA Actions to Address Environmental Justice in Minority Populations and Low-Income Populations”, DOT 

Order 6640.23 (1998) available at http://www.fhwa.dot.gov/legsregs/directives/orders/6640_23.htm. 

95 TDOT, Tennessee Environmental Procedures Manual: Guidelines for Preparing Environmental Documentation for 

Federally Funded and State Funded Transportation Projects, April 2007. 

Table 3-7: Population Characteristics 

Geographical 

Area 

Percent 

Minority 

Population 

Percent 

Population 

Under Age 18 

Percent 

High School 

Graduates 

Median 

Household 

Income 

Percent 

Below 

Poverty Line

Tennessee 19.9 24.6 75.9 36,360 13.5 

Fayette County 37.5 25.7 70.6 40,279 14.3 

CT 607 38.1 24.6 73.3 42,165 13.9 

BG 3 44.6 22.9 71.1 40,833 11.8 

Mississippi 39.3 27.3 72.9 31,330 19.9 

Marshall 

County 52.3 26.6 61.0 28,756 21.9 

CT 9501 39.1 26.4 35.5 29,963 16.9 

BG 3 26.0 49.0 NA NA NA 

Source: US Census Bureau, 2000 

Note: CT= U.S. Census Tract; BG=U.S. Census Block Group; NA=Not Available 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-33 

6/30/2010 

project on minority and/or low- income populations would 

be expected to be the same as those on non-minority 

and/or non-low-income populations. Consequently, the 

project would not have a disproportionately high or 

adverse effect on minority and/or low-income populations. 

Additionally, all the people living in the project area would 

potentially share the benefits of the proposed project. 

3.4.2.1 Low-Income Populations 

As Figure 3-12 illustrates, the area around the proposed 

Memphis Regional IMF does not have a high concentration 

of low income population as defined by applicable EPA 

guidance and other federal guidelines. According to the 

2000 Census, the Memphis Regional IMF area 

surrounding the project has a lower percentage of low 

income population, approximately 11.8% (Block Group 3) 

then the larger Census Tract 607 (13.9%) or Fayette 

County (14.3%). The average per capita income for 

residents in Block Group 3 is $42,165, which is higher than 

the Fayette County-wide average of $40,279. The nearest 

low income neighborhood, based on information from the 

Town of Rossville, is located on Morrison Road, 

approximately 1.7 mile from the Memphis Regional IMF. 

Several low income families live on Knox Road southeast 

of the facility. The Memphis Regional IMF will not have a 

disproportionate impact directly or indirectly on the 

Morrison Road neighborhood or the low income families 

living on Knox Road due to distance and intervening 

topography.

In Marshall County, Mississippi, approximately 21.9% of 

the county’s population is living below the poverty line. 

The Marshall County Census Tract 9501 has 

approximately 16.9% of the population living below the 

poverty line. In Marshall County Census Tract 9501, the 

average per capita income is higher in the project area 

($29,963) than in the overall county ($28,756). The 

closest neighborhoods in Mississippi to the Memphis 

Regional IMF are not considered low income. The nearest 

low income neighborhood identified is located off of US 

Hwy 72 approximately 0.5 mile west of the intersection of 

US Hwy 72 and Industrial Road. The low income 

neighborhood is approximately 2.0 miles southwest of the 

proposed Memphis Regional IMF.96 Due to the distance 

and intervening topography the Memphis Regional IMF will 

not have a disproportionate impact on the low income 

neighborhood off of US Hwy 72. 

 

96 Personal Communication with Executive Director, Marshall County Industrial Development Authority, March 2010. 
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Figure 3-12: Percent Poverty from 2000 Census (Block Group Level) 
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3.4.2.2 Minority Populations 

Figure 3-13 illustrates the distribution of the minority 

population across the study area. Census Block Group 3 

(BG 3), which includes the majority of the project area, 

contains a 44.6% minority population. Rossville has a 

lower minority population of 28.1% (105 individuals). The 

Memphis Regional IMF is within the Rossville growth 

boundary. No minority neighborhoods have been 

identified adjacent or near to the Memphis Regional IMF 

and therefore, no disproportionate impacts to minority 

neighborhoods are anticipated. The two closest 

neighborhoods with predominantly minority populations, 

based on discussions with local officials, include a 

neighborhood located approximately 2 miles north of 

downtown Rossville off SR-194 and a neighborhood 

located approximately 1.50 miles east of downtown 

Rossville off Mt. Pleasant Drive).97 The minority 

neighborhoods are approximately 5.2 miles and 4.0 miles 

from the proposed Memphis Regional IMF and no adverse 

impacts to these neighborhoods are anticipated. 

According to the 2000 Census, minority populations 

comprise 39.3% of the population in Mississippi and 52.3% 

in Marshall County. A portion of Industrial Road lies within 

Census Tract 9501 and Block Group 3. Minority 

populations comprise 39.1% of Census Tract 9501 and 

26% of Block Group 3. The percentage of minority 

populations within Block Group 3 is lower than the 

percentage in Marshall County and the State of 

Mississippi. 

In summary, there is no evidence that any low-income or 

minority populations or neighborhoods with predominantly 

low-income or minority populations would bear any 

adverse effects as a result of Build Alternative 1. Even 

during construction, area roads would remain unimpeded 

in order to ensure safe and uninterrupted passage for area 

residents to places of worship, community services, 

government assistance offices and hospitals. Social 

interactions within the community would continue 

unhindered. There are no anticipated impacts associated 

with Build Alternative 1 concerning social isolation, 

segmentation or disruption of local communities. 

Although no special needs or impacts associated with 

minority or low-income populations have been identified at 

this time, FRA acknowledges that these needs may be 

identified during further public involvement meetings held 

 

97 Personal communication with Planning and Zoning Department representative, Town of Rossville, 10/27/2009. 
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regarding the project.98 Should such needs arise at a later 

date, FRA would insure NSR addresses the needs through 

the design phase, the public involvement process, and any 

further environmental process. 

Figure 3-13: Percent Minority from 2000 Census (Block Group Level) 

In accordance with Title VI of the Civil Rights Act of 1964, 

TDOT would comply with Title VI to ensure that “No person 

shall be, on the grounds of race, color or national origin, 

excluded from participation in, denied the benefits of, or 

subjected to discrimination under any program or activity 

receiving Federal assistance.” 

3.4.3 Existing Community Services 

Build Alternative 1 is not anticipated to represent a barrier 

to social interaction. Construction of the proposed project 

would result in temporary or minor impacts to residents in 

the project area. No business or residential relocations 

 

98 EPA Final Guidance for Incorporating Environmental Justice Concerns in EPA's NEPA Compliance Analyses available 

at http://www.epa.gov/compliance/resources/policies/ej/ej_guidance_nepa_epa0498.pdf. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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would occur due to Build Alternative 1. Therefore, other 

than short-term, construction-related effects (e.g., noise 

and alterations in traffic and traffic patterns), this project is 

not anticipated to have any adverse community service 

impacts. 

3.4.4 Social Impacts 

Build Alternative 1 would not represent a barrier to social 

interaction or community cohesion. There are no schools, 

churches, or hospitals located within the project site. The 

nearest schools are located in Piperton and Rossville 

proper. Two churches are located near the site. One 

church, the Golden Jerusalem M.B. Church is located 

approximately 0.6 mile west from the proposed SR-57 

overpass and the second church, St. Luke’s Church 

(Photo 3-5), is located on Knox Road approximately 0.5 

mile east of the lead tracks. The closest hospitals are 

located in Collierville, Tennessee, and Holly Springs, 

Mississippi. 

It is likely that residents in the immediate area would 

experience temporary or minor impacts as a result of 

construction of Build Alternative 1. These impacts are not 

expected to be substantial. There would be some shortterm construction-related impacts (e.g., noise and 

alterations in access and traffic patterns), but Build 

Alternative 1 is not anticipated to have any adverse, longterm social impacts. Potential impacts are as follows: 

 Residents/Neighborhoods. Residents on Neville 

Road in Tennessee may experience an increase in 

noise levels from train traffic. Residents on North 

Lenderman Road in Tennessee and Mississippi 

may experience a similar increase in noise levels 

along with increased congestion due to truck traffic. 

See Section 3.8 for additional discussion about 

noise levels. 

 Schools (and school buses). No schools are 

located in the project area. Local school buses 

utilize the section of US Hwy 72, where the 

construction and operating traffic would enter the 

facility. Some school buses travel on SR-57, which 

would be placed on a temporary bypass while the 

grade separation overpass is constructed over the 

lead tracks to the facility. 

 Industries. The Memphis Regional IMF would be 

operated by approximately 140 employees, 65% of 

whom are expected to be shift workers. Additional 

short-term jobs would be created both on- and offsite during construction and IMF operation. 
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 Community Services and Facilities. The facility 

should have no effect on existing daycare, 

churches, or civic groups. The facility might cause 

a slight increase in the need for fire, police, hospital 

or other type of emergency services. Emergency 

services would be provided by the Town of 

Rossville in Fayette County, Tennessee. 

There are no adverse social impacts from the No-Build 

Alternative. 

3.4.5 Security Impacts 

The Memphis Regional IMF would be fenced and/or have 

other physical barriers and close-circuit monitoring to 

protect areas from unauthorized access. The final decision 

on fencing and security measures would be made during 

the project design phase. Gates would control personnel 

and vehicles moving, entering, or leaving the Memphis 

Regional IMF. Measures to enhance boundaries/access 

points include clear zones, security lighting in selected 

areas, locks, and signage. Security around and within the 

facility should not have a negative impact on the area and 

are not expected to be substantial. 

There are no security impacts from the No-Build 

Alternative. 

3.5. Displacements 

Build Alternative 1 would not result in residential or 

business relocations. 

There are no relocations associated with the No-Build 

Alternative. 

3.6. Economic Impacts 

3.6.1 Existing Economic Conditions 

As of November 2009, the Tennessee Department of 

Labor and Workforce Development estimate that the 

Fayette County labor force was 17,820 with 15,780 

employed and 2,040 unemployed. The Fayette County 

unemployment rate was 11.4%, which is higher than the 

statewide rate of 10.1%.99 

The Tennessee Advisory Commission on 

Intergovernmental Relations (TACIR) estimates that the 

largest major industry sector in Fayette County (as of 

 

99 Tennessee Department of Labor and Workforce Development, “Labor Force Estimates – United States & Tennessee, 

December 23, 2009. 
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2007) was Manufacturing (30.9% of the employment), 

followed by Government (23.1%), then Trade, 

Transportation and Utilities (12.9%). The three largest 

companies in Fayette County in 2009 were The Troxel 

Company (401 employees), Kellogg's Convenience Foods 

(350 employees) and Medegen Medical Products (250 

employees).100

As of September 2009, the Mississippi Department of 

Employment Security (MDES), Labor Market Information 

Department estimates that the Marshall County labor force 

was 14,859.101 The Marshall County unemployment rate 

was 11.2%, which is higher than the statewide rate of 

8.8%. According to the Marshall County Industrial 

Development Authority, the following five 

companies/facilities are the largest employers in the 

county, each of which employs between 200-400 people: 

1) Hunter Fan; 2) Thomas and Betts Electrical Supply 

Company; 3) Parker Hannifin; 4) Exel Corporationdistribution carrier; and 5) Marshall County Corrections 

Facility.102 

The Marshall County Industrial Development Authority has 

sites available for industrial growth.103 The Chickasaw 

Trail Industrial Park (an independent development) 

consists of 2,600 acres zoned industrial and available sites 

in the municipalities of Holly Springs, Byhalia and Potts 

Camp, each town located along US Hwy 78 in Mississippi.

3.6.2 Economic Impacts 

Build Alternative 1 would positively affect economic 

conditions in Fayette and Marshall Counties. The 

Memphis Regional IMF would be an investment of over 

$129 million dollars. It would be operated by 

approximately 140 employees, 65% of whom are expected 

to be shift workers. Additional short-term jobs would be 

created both on- and off-site during construction and site 

development. At this time, it is anticipated that most 

employees would be from Fayette, Shelby and Marshall 

Counties as well as the surrounding region. This creation 

of employment would result in additional personal income 

for the purchase of goods and services within the region. 

 

100 www.tennessee.gov/tacir. 

101 Mississippi Department of Employment Security, Labor Market Information Department - www.mdes.ms.gov

(10/25/09) 

102 Personal communication with representative from the Industrial Development Authority (IDA) of Marshall County, MS 

on 10/23/09. 

103Marshall County, MS, “Economic Development Assets in Marshall County,” 

http://www.marshallcoms.com/Economic_Development/econdev.html. 
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The benefits noted in Section 1 and attributable to the 

Memphis Regional IMF when it is fully operational, are 

expected to include nationwide more than $81.4 million in 

annual congestion savings nationwide, avoidance of an 

estimate $20.7 million in highway crashes and fatalities 

costs nationwide104, and 6,186 new or benefited jobs for 

the region.105 In this context, a benefited job is one at a 

company that uses intermodal transportation to reduce 

costs and consequently is more profitable such that the job 

is more secure. 

The additional persons using the facility should benefit 

local gas stations and restaurants. Further indirect and 

cumulative economic impacts are discussed in Section 

3.18.4. 

Another economic impact of Build Alternative 1 is the 

potential taxes payable by NSR and others related to the 

construction and operation of the Memphis Regional IMF 

and the development it is projected to attract. 

Build Alterative 1 is located in an area characterized by 

average weekly wages and median household incomes 

that are higher than the statewide average. It is expected 

that the proposed project would have a positive economic 

impact on the area. 

The No-Build Alternative would have no economic impact 

in the Fayette and Marshall County areas. The 

employment opportunities associated with a new IMF 

would not occur. The unemployment rates in Fayette and 

Marshall Counties would be expected to continue at their 

current levels of over 11%. 

3.7. Air Quality Impacts 

Air pollution is a general term that refers to one or more 

chemical substances that degrade the quality of the 

atmosphere. Air quality describes the amount of pollution 

in the air, with good air quality representing acceptable 

concentrations of air pollutants and poor air quality 

indicating unacceptable concentrations of air pollutants. 

Individual air pollutants degrade the atmosphere by 

reducing visibility, damaging property, reducing productivity 

or vigor of crops or natural vegetation, or reducing human 

or animal health. 

 

104 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010.. 

105 Insight, May 2009.. 
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3.7.1 Existing Air Quality Designation 

The ambient air quality in an area can be characterized 

with respect to compliance with the primary and secondary 

National Ambient Air Quality Standards (NAAQS). The 

Clean Air Act, as amended (CAAA)106, requires the U.S. 

EPA to set NAAQS for pollutants considered harmful to 

public health and the environment. Currently, EPA has set 

NAAQS for six principal pollutants, called criteria 

pollutants: carbon monoxide (CO); lead (Pb); nitrogen 

dioxide (NO2); sulfur dioxide (SO2); ozone (O3); and 

respirable particulate matter (PM), including PM with an 

aerodynamic size less than or equal to 10 micrometers 

(PM10) and PM with an aerodynamic size less than or 

equal to 2.5 micrometers (PM2.5). The Federal standards 

adopted by EPA set allowable concentrations and 

exposure limits for various pollutants. Title I of the CAA 

established criteria for attaining and maintaining the 

NAAQS. The NAAQS include two types of air quality 

standards. The Primary Standards are established to 

protect public health. Secondary Standards are 

established to protect public welfare and the environment. 

In promulgating the Primary Standards for protection of 

public health, EPA evaluated environmental health effects 

including establishing a margin of safety to protect children 

and other sensitive populations. Secondary Standards 

include protection against decreased visibility, damage to 

animals, crops, vegetation, and buildings.107 These 

pollutants, when present at concentrations that exceed 

NAAQS, are believed to be detrimental to public health 

and the environment and to cause property damage. 

Fayette County, Tennessee, and Marshall County, 

Mississippi, are designated as in attainment for all NAAQS; 

therefore, the current air quality in the location of the 

proposed project is not a concern. 

3.7.2 Conformity Analysis 

Transportation Conformity is a way to ensure that Federal 

funding and approval are given to those transportation 

activities that are consistent with air quality goals. It 

ensures that these transportation activities do not worsen 

air quality or interfere with the "purpose" of the State 

Implementation Plan (SIP), which is to meet the 

NAAQS.108 Transportation Conformity is a process 

required of Metropolitan Planning Organization (MPO) 

 

106 CAA, 42 U.S.C. s/s 7401 et seq. 

107 EPA National Ambient Air Quality Standards for Particulate Matter, 71 Fed. Reg. 61,144 (Oct. 17, 2006). 

108 EPA and FHWA, “Transportation Conformity Guidance for Qualitative Hot-Spot Analyses in PM2.5 and PM10

Nonattainment and Maintenance Areas,” 2006, EPA 420-B-06-902, 

www.fhwa.dot.gov/environment/conformity/pmhotspotguid.htm. 
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pursuant to the CAAA, which requires federally assisted 

transportation plans, transportation improvement 

programs, and transportation projects such as IMFs to be 

consistent with or “conform to” the purpose or intent of the 

SIP for a given area.109

In terms of demonstrating conformity to a SIP's purpose of 

eliminating or reducing the severity and number of 

violations of the NAAQS (as well as achieving expeditious 

attainment of the NAAQS), the CAAA require that Federal 

actions may not cause or contribute to a new violation of a 

standard in the area significantly affected by the project or 

over a region which would otherwise not be in violation of 

the standard during the future period in question, if the 

project were not implemented; or increase the frequency or 

severity of any existing violation. Conformity is satisfied for 

projects in nonattainment and maintenance areas if it is 

demonstrated that during the time frame of the 

transportation plan no new local violations would be 

created and the severity or number of existing violations 

would not be increased as a result of the project. 

Transportation Conformity applies to nonattainment and 

maintenance areas for O3, CO, PM2.5, PM10, and NO2.110

Fayette County, Tennessee, and Marshall County, 

Mississippi, are designated in attainment for all of the 

Transportation Conformity regulated criteria pollutants. 

A portion of Fayette County near Rossville, Tennessee, 

remains under a maintenance plan until 2015 to ensure 

that air quality remains in attainment of the Pb NAAQS. 

However, the project site is located outside the 

maintenance plan coverage. Therefore, the location of 

the proposed Memphis Regional IMF is in attainment for 

the Pb NAAQS. 

Fayette County, Tennessee, and Marshall County, 

Mississippi, are in attainment for all of the Transportation 

Conformity regulated criteria pollutants, thus, under the 

Transportation Conformity requirements; a conformity 

determination is not required. Tennessee Department of 

Environment and Conservation (TDEC) concurred with this 

determination in a letter dated November 17, 2009, in 

Appendix A. In addition, because the Memphis Regional 

IMF will receive funding from the U.S. Department of 

Transportation, Transportation Investment Generating 

Economic Recovery (TIGER) Program as part of the 

American Recovery and Reinvestment Act (ARRA) of 

 

109 EPA and FHWA 2006. 

110 EPA and DOT. “Guidance for the Use of Latest Planning Assumptions in Transportation Conformity Determinations, 

Revision to January 18, 2001 Guidance Memorandum,” December 2008. 
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2009, the Transportation Conformity requirements of the 

CAA do not apply. 

The General Conformity Rule ensures that actions taken 

by federal agencies in nonattainment and maintenance 

areas meet national standards for air quality. Established 

under the Clean Air Act (section 176(c)(4)), the General 

Conformity Rule plays an important role in helping states 

and tribal regions improve air quality in those areas that do 

not meet the National Ambient Air Quality Standards 

(NAAQS). Under the General Conformity Rule, Federal 

agencies must work with State, Tribal and local 

governments in a nonattainment or maintenance area to 

ensure that federal actions conform to the initiatives 

established in the applicable state or tribal implementation 

plan. 

As noted above, Fayette County is designated in 

attainment for all NAAQS. A portion of the county near 

Rossville, however, was historically designated as 

nonattainment for Pb in 1993, and then re-designated as 

attainment in 1995. This area, therefore, remains under a 

maintenance plan until 2015 to ensure that air quality 

remains in attainment of the Pb NAAQS. 

The established limit for Pb in a maintenance area is 25 

tons per year (tpy). However, there are no reasonably 

foreseeable emissions of Pb associated with the Memphis 

Regional IMF project. The only consequential stationary 

source of Pb in Fayette County was the Ross Metals 

facility which was closed in 1992. The predominant 

emissions associated with the IMF would be fugitive dust 

emissions during construction and mobile source 

emissions during both construction and operation. Only 

minor (or exempt) stationary sources of air emissions such 

as ASTs and an emergency generator are anticipated to 

be associated with the IMF. Gasoline no longer contains 

Pb additives although both gasoline and diesel contain 

trace levels of naturally-occurring Pb. 

No substantial emissions of Pb are anticipated with the 

construction and operation of the proposed IMF 

consequently the General Conformity emission thresholds 

will not be exceeded. In addition, the project site is located 

outside the maintenance plan coverage. Fayette County is 

designated as attainment for all other criteria pollutants. 

Therefore, the project will not be subject to the General 

Conformity requirements. 

3.7.3 Evaluate Air Quality 

With Build Alternative 1 being located in an area 

designated as in attainment for all applicable air pollutants, 
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a detailed analysis of the emission and subsequent 

dispersion of air pollutants was not required. Some air 

quality analysis was still undertaken to evaluate impacts. 

Analysis of aerial photography of the project vicinity 

indicates that approximately 55 residences are located 

within 1⁄2 mile of the project limits, including the SR-57 

overpass. Another approximate 20 residences are located 

within 1⁄2 mile of the Industrial Road. These residences 

and other sensitive populations (e.g. schools, nursing 

homes, day cares, hospitals, parks etc.) in the area are 

illustrated on the map in Figure 3-14. 

The Memphis Regional IMF would have capacity to 

perform 327,000 lifts of containers and trailers from and to 

rail cars annually. Air emissions from the IMF would be 

comprised almost entirely of exhaust emissions from diesel 

powered locomotives, trucks, and IMF support equipment 

The emission producing activities that would occur at the 

facility once it is operational would include the following: 

 Mobile source emissions from semi-tractor trailers 

and/or bobtails entering and/or exiting the facility, 

including travel on Industrial Road. 

 Mobile source emissions associated with the 

movement of containers and trailers within the yard, 

including the use of cranes, hostler trucks, and side 

loaders. 

 Mobile source emissions from locomotive 

movement in the yard including locomotives moving 

on the lead tracks, in the support yard, or on the 

loop track. 

 Mobile source emissions from maintenance trucks 

present at the facility. 

 Mobile source emissions from employee vehicles, 

including travel on Industrial Road. 

 Exempt stationary source emissions associated 

with diesel fuel combustion in an emergency 

generator. 

 Insignificant stationary source emissions of volatile 

organic compounds (VOCs) from aboveground 

storage tanks (ASTs) that would be present at the 

yard for the storage of petroleum products including 

lubrication oil and diesel fuel. 
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Figure 3-14: Sensitive Population Locations 

3.7.3.1 Mobile Source Air Toxics (MSATs) 

A discussion of mobile source air toxics (MSATs) as it 

relates to proposed Memphis Regional IMF is presented in 

the following text. The non-project specific MSAT 

discussion is drawn substantially from the Federal Highway 

Administration’s (FHWA) Interim Guidance Update on 

Mobile Source Air Toxic Analysis in NEPA Documents.111

Controlling air toxic emissions became a national priority 

with the passage of the CAAA of 1990, whereby Congress 

 

111 Federal Highway Administration (FHWA), Interim Guidance Update on Mobile Source Air Toxic Analysis in NEPA 

Documents, September 30, 2009. 
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mandated that the EPA regulate 188 air toxics, also known 

as hazardous air pollutants. The EPA has assessed this 

expansive list in their latest rule on the Control of 

Hazardous Air Pollutants from Mobile Sources (Federal 

Register, Vol. 72, No. 37, page 8430, February 26, 2007) 

and identified a group of 93 compounds emitted from 

mobile sources that are listed in their Integrated Risk 

Information System (IRIS).112 In addition, EPA identified 

seven compounds with significant contributions from 

mobile sources that are among the national and regionalscale cancer risk drivers from their 1999 National Air 

Toxics Assessment.113 These are acrolein, benzene, 1,3-

butadiene, diesel particulate matter plus diesel exhaust 

organic gases (diesel PM), formaldehyde, naphthalene, 

and polycyclic organic matter. While FHWA considers 

these the priority mobile source air toxics, the list is subject 

to change and may be adjusted in consideration of future 

EPA rules. 

The 2007 EPA rule mentioned above requires controls that 

will dramatically decrease MSAT emissions through 

cleaner fuels and cleaner engines. According to an FHWA 

analysis using EPA's MOBILE6.2 model, even if vehicle 

activity (vehicle-miles traveled, VMT) increases by 145 

percent as assumed, a combined reduction of 72 percent 

in the total annual emission rate for the priority MSAT is 

projected from 1999 to 2050 as presented in Figure 3-15 

Air toxics analysis is a continuing area of research. While 

much work has been done to assess the overall health risk 

of air toxics, many questions remain unanswered. In 

particular, the tools and techniques for assessing projectspecific health outcomes as a result of lifetime MSAT 

exposure remain limited. These limitations impede the 

ability to evaluate how the potential health risks posed by 

MSAT exposure should be factored into project-level 

decision-making within the context of the NEPA. 

Nonetheless, air toxics concerns continue to be raised on 

highway projects during the NEPA process. Even as the 

science emerges, it is duly expected by the public and 

other agencies that MSAT impacts be addressed in 

environmental documents. The FHWA, EPA, the Health 

Effects Institute, and others have funded and conducted 

research studies to try to more clearly define potential risks 

from MSAT emissions associated with highway projects. 

 

112 http://www.epa.gov/ncea/iris/index.html. 

113 NATA, http://www.epa.gov/ttn/atw/nata1999/. 
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On February 3, 2006, the FHWA released “Interim 

Guidance on Air Toxic Analysis in NEPA Documents.”114 

This guidance was superseded on September 30, 2009 by 

FHWA’s “Interim Guidance Update on Air Toxic Analysis in 

NEPA Documents”. The purpose of FHWA’s guidance is 

to advise on when and how to analyze MSATs in the 

NEPA process for transportation-related projects. 

Figure 3-15: National MSAT Emission Trends 1999 – 2050 for Vehicles 

Operating on Roadways Using EPA's MOBILE6.2 Model 

Note: 

(1) Annual emissions of polycyclic organic matter are projected to be 561 tons/yr for 1999, decreasing 

to 373 tons/yr for 2050. 

(2) Trends for specific locations may be different, depending on locally derived information representing 

vehicle-miles traveled, vehicle speeds, vehicle mix, fuels, emission control programs, meteorology, and 

other factors 

Source: U.S. Environmental Protection Agency. MOBILE6.2 Model run 20 August 2009. 

FHWA’s 2009 Interim Guidance groups projects into the 

following categories, each with an expected level of MSAT 

analysis: 

Level 1 - Exempt Projects and Projects with no 

Meaningful Potential MSAT Effects – no MSAT 

analysis required; 

Level 2 - Projects with Low Potential MSAT Effects – 

these are projects “that serve to improve operations of 

 

114 FHWA, Interim Guidance on Air Toxics Analysis in NEPA Documents, February 3, 2006. 
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highway, transit or freight without adding substantial 

new capacity or without creating a facility that is likely 

to meaningfully increase MSAT emissions” – qualitative 

MSAT assessment required; and, 

Level 3 - Projects with Higher Potential MSAT Effects - 

these include projects that “create or significantly alter 

a major intermodal freight facility that has the potential 

to concentrate high levels of diesel particulate matter in 

a single location” . . . and are “proposed to be located 

in proximity to populated areas.” 

The proposed Memphis Regional IMF is the construction 

and operation of a new intermodal facility. As noted 

previously, the location of the facility is rural with only 

approximately 55 residences located within 1⁄2 mile of the 

project limits and with another approximate 20 residences 

located within 1⁄2 mile of the Industrial Road. There are no 

sensitive population (e.g., schools, hospital, nursing 

homes, day cares, etc.) identified within 1⁄2 mile of the 

facility, Figure 3-15. Therefore, the project is considered to 

fall within the Level 2 category of projects with low potential 

MSAT effects that require a qualitative assessment of 

MSATs. To confirm this designation, both a qualitative and 

an initial quantitative analysis of MSAT emissions were 

conducted. Each Build Alternative, if taken to the 

preliminary design stage, would have evaluated an IMF 

with a maximum design capacity of 327,000 

container/trailer lifts annually. 

As outlined by FHWA for Transportation and Toxic Air 

Pollutants, Appendix B - Examples of Prototype Language 

for Qualitative Project Level MSAT Discussions is 

presented below. For each alternative in this EA, the 

amount of MSATs emitted would be proportional to the 

amount of truck vehicle miles traveled (VMT) and rail 

activity, assuming that other variables (such as travel not 

associated with the intermodal facility) are the same for 

each alternative. The truck VMT and rail activity estimated 

for the Build Alternatives are higher than those for the No 

Build Alternative because of the additional activity 

associated with the intermodal facility. 

An analysis of the Industrial Road Alternative, i.e., Build 

Alternative 1, presented below in Table 3-8, indicates that 

an additional 5,838 VMT per day are estimated in 

association with the proposed Memphis Regional IMF. 

The diversion of these units and their associated VMT 

would produce significant reductions in: highway hours of 

travel (over 3 million hours); fuel consumption (nearly 24 

million gallons); CO2 emissions (over 265,000 tons); and 

highway crashes avoided (185). In 2015, the Memphis 
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Regional IMF is projected to handle 186,798 loaded units 

(containers and trailers) of traffic to and from Northeastern 

US points that currently move all-highway. Diverting this 

number of units from truck to rail would save more than 

185 million miles of truck VMT, because the average 

length of the diverted truck trips is around 1000 miles each. 

The largest number of units would be removed from 

highways in Tennessee, Virginia, West Virginia, Maryland, 

and Pennsylvania, but there would also be units removed 

from highways in Delaware and New Jersey.115

Table 3-8: 2015 Design Year VMT Projections on Industrial Road and IMF 

Alternative LOCAL 

Year 2015 VMT per day 

NON-LOCAL 

(Regional/National) 

Year 2015 VMT per day 

No-Build Alternative 0 478 million VMT per dayb

Industrial Road Alternative 5,838 VMT per daya 0 

a

 VMT for Industrial Road and travel on the facility is estimated at 6 miles round trip for 834 trucks 

per day and 139 employee vehicles per day. 

b

 VMT No-Build is estimated at 938 miles trip between Memphis International Airport and NSR PA 

Zero IMF Harrisburg PA for 186 million trucks per year. 

This increase in truck VMT and rail activity associated with 

the Build Alternatives would lead to higher MSAT 

emissions (particularly diesel particulate matter) in the 

vicinity of the intermodal facility. The higher emissions 

could be offset somewhat by two factors: 1) the decrease 

in regional truck traffic due to increased use of rail for 

inbound and outbound freight; and 2) increased speeds on 

area highways due to the decrease in truck traffic. The 

extent to which these emissions decreases would offset 

intermodal center-related emissions increases is not 

known. However, NSR has committed to the use of ultra 

low-sulfur transportation grade diesel fuel (0.0015 percent 

sulfur) for NSR container and trailer handling equipment. In 

addition, NSR will use Tier 4 technology in the overhead lift 

cranes at the proposed Memphis Regional IMF. 

Near-roadway health studies indicated that elevated 

concentrations of pollutants emitted from motor vehicles 

near large roadways generally occur within approximately 

200 meters (approximately 650 feet) of the road, although 

the distance may vary depending on traffic and 

 

115 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 
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environmental conditions, with concentrations returning to 

background levels beyond this distance.116 

Because the estimated truck VMT and rail activity under 

each of the Build Alternatives are nearly the same, varying 

by less than one percent, it is expected there would be no 

appreciable difference in overall MSAT emissions among 

the various alternatives since the same annual lifts would 

be used at any alternative which meets the need and 

purpose. Only alternatives with a capacity of 327,000 

container/trailer lifts annually would meet the need and 

purpose as discussed in Section 1.3. Also, regardless of 

the alternative chosen, emissions would likely be lower 

than present levels in the design year as a result of EPA's 

national control programs that are projected to reduce 

annual MSAT emissions by 72 percent from 1999 to 2050. 

Local conditions may differ from these national projections 

in terms of fleet mix and turnover, VMT growth rates, and 

local control measures. However, the EPA-projected 

reductions are so significant (even after accounting for 

VMT growth) that MSAT emissions in the study area are 

likely to be lower in the future as well. 

The additional freight activity contemplated as part of the 

project alternatives would have the effect of increasing 

diesel emissions in the vicinity of nearby homes, schools, 

and businesses; therefore, under each alternative there 

may be localized areas where ambient concentrations of 

MSAT would be higher than under the No Build alternative. 

The localized differences in MSAT concentrations would 

likely be most pronounced as outlined in Table 2-2 at the 

Expansion of Forrest Yard (Alternative 3) and Pigeon Park 

(Alternative 6) due to increased urbanization of and nonattainment issues with these Memphis area alternatives. 

In addition, East Rossville (Alternative 2) could impact a 

minority neighborhood along with other sensitive 

populations in Rossville. The Pictsweet (Alternative 4) and 

Vulcan (Alternative 5) could impact a lower income 

neighborhood. However, as discussed above, the 

magnitude and the duration of these potential differences 

cannot be reliably quantified due to incomplete or 

unavailable information in forecasting project-specific 

health impacts. Even though there may be differences 

among the Alternatives, on a region-wide basis, EPA's 

vehicle and fuel regulations, coupled with fleet turnover, 

would cause substantial reductions over time that in almost 

all cases the MSAT levels in the future will be significantly 

lower than today. 

 

116 EPA, Regulatory Impact Analysis Control of Hazardous Air Pollutants from Mobile Sources Chapter 3 Air Quality and 

Resulting Health and Welfare Effects of Air Pollution from Mobile Sources, Office of Transportation and Air Quality, 

EPA420-R-07-002 February 2007. 
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If the Memphis Regional IMF were not constructed, it is 

reasonable to presume that rail activity would remain at 

somewhat comparable levels on the existing NSR mainline 

tracks, and the vehicles, including the employee vehicles 

and container trucks, would be still be present on the local 

highway and interstate system. 

In summary, the increase in local emissions due to facility 

operation would be offset regionally by three factors: 

1) The decrease in long-haul truck traffic due to the 

increased use of rail for inbound and outbound 

freight; 

2) A reduction in MSAT emissions associated with 

future reductions in domestic cargo transfers at the 

NSR Forrest IMF in Memphis; and 

3) Decreased roadway congestion on area highways 

which would allow vehicles to consistently travel at 

posted speeds. 

One of the advantages of the project is that future longhaul highway truck traffic between Memphis and the 

Northeast would be reduced by an estimated 186 million 

loaded truck vehicle miles per year117; thereby considerably 

reducing air emissions, including MSATs on a large-scale 

regional and national basis. In addition, NSR will shift some of 

their domestic intermodal capacity from the Forrest IMF to the 

new facility. 

The existing NSR Forrest IMF is located in a highly urban 

setting within the City of Memphis and handles both 

international and domestic intermodal shipments. Forrest IMF 

is surrounded by lower income and minority population, plus 

other sensitive population. The Memphis Regional IMF would 

have a maximum design capacity of 327,000 

container/trailer lifts annually, which would include the 

domestic capacity reductions from the Forrest IMF. Even 

with a projected growth in the international shipments, the shift 

of domestic capacity to the new facility is expected to result in 

an approximate 27% reduction of lifts performed at the Forrest 

IMF on an annual basis. This reduction would not only result 

in a decrease in truck traffic in the vicinity of the Forrest IMF, 

but NSR also anticipates that the number of intermodal trains 

servicing the Forrest IMF would be reduced from four to two. 

Therefore, the net reduction in intermodal freight transfers at 

the Forrest IMF will result in a corresponding net reduction in 

MSAT emissions. 

 

117 NSR 2010. 
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The decreased congestion on area highways and city 

streets near the Forrest IMF would allow vehicles to 

consistently travel at posted speeds. According to EPA's 

MOBILE6.2 Vehicle Emissions Model, emissions of all of 

the priority MSATs decrease as speed increases (except 

for DPM which MOBILE6.2 estimates as constant with 

speed).118 Implementation of the EPA’s mobile source 

vehicle emissions standards and fuel programs will result 

in an estimated 98 percent reduction in allowable PM 

emissions and a 97 percent reduction in allowable NOx 

emissions from new heavy duty on-road trucks after 

2010.119

In addition, EPA has promulgated increasingly more 

stringent emission standards for locomotive engines and 

support equipment, as well as more stringent requirements 

on the fuels they use, such that MSAT emissions from rail 

activity in the study area are also likely to be lower in the 

future. The locomotive diesel engines designed to meet 

the more stringent standards will achieve PM reductions of 

90 percent and NOx reductions of 80 percent, and these 

new standards will also yield sizeable reductions in 

emissions of nonmethane hydrocarbons (NMHC), CO, and 

air toxics.120 Regulations include 40 CFR 80121, 40 CFR 

89122, 40 CFR 92123, 40 CFR 1033124, and 40 CFR 

1039125 (see also 69 FR 38958126 and 73 FR 37096127). 

In sum, all Build Alternatives in the design year are 

expected to be associated with higher levels of MSAT 

emissions in the study area, relative to the No Build 

Alternative, along with some benefit from improvements in 

speeds and reductions in region-wide truck traffic. There 

also could be slightly higher differences in MSAT levels 

among Alternatives in a few localized areas where freight 

activity occurs closer to homes, schools, and businesses. 

Under all alternatives, MSAT levels are likely to decrease 

 

118 EPA, Mobile6.2 Vehicle Emission Modeling Software, 2004, http://www.epa.gov/otaq/m6.htm. 

119 FHWA, Recent Examinations of Mobile Source Air Toxics, 2010, 

http://www.fhwa.dot/environment/airtoxic/msatcompare/index.htm. 

120 EPA, Regulatory Impact Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine 

Compression Ignition Engines Less than 30 Liters Per Cylinder, Office of Transportation and Air Quality, EPA420-R-08-

001a, May 2008. 

121 EPA, 40 CFR 80, Regulation of Fuels and Fuel Additives, Subpart I, Motor Vehicle, Nonroad, Locomotive, and Marine 

Diesel Fuel. 

122 EPA, 40 CFR 89, Control of Emissions from New and In-Use Nonroad Compression-Ignition Engines. 

123 EPA, 40 CFR 92, Control of Emissions from Locomotives and Locomotive Engines. 

124 EPA, 40 CFR 1033, Control of Emissions from Locomotives. 

125 EPA, 40 CFR 1039, Control of Emissions from New and In-Use Nonroad Compression-Ignition Engines. 

126 Federal Register, 69FR38958, Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel. 

127 Federal Register, 73FR 37096, Control of Emissions of Air Pollution from Locomotive Engines and Marine CompressIgnition Engines Less than 30 Liters per Cylinder (republication). 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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over time due to nationally mandated cleaner vehicles and 

fuels. 

FHWA and EPA have provided guidance to define what 

would constitute an “air quality project of concern” for 

demonstrating transportation conformity in nonattainment 

or maintenance areas.128 This guidance is specific to 

projects of air quality concern for particulate matter. 

Although a conformity determination under Transportation 

Conformity is not required for this project, the FHWA/EPA 

guidance suggests that projects with greater than 125,000 

annual average daily traffic (AADT) volumes and with more 

than 8 percent of the AADT as diesel truck traffic are 

considered “air quality projects of concern.” The FHWA 

interim MSAT guidance indicates that projects that create 

new or add significant capacity to highways with traffic 

volumes where the AADT is projected to be in the range of 

140,000 to 150,000 or greater by the design year are 

projects with higher potential MSAT effects (i.e., Level 3 

projects).129 

The maximum expected increase in truck traffic at the 

proposed facility is only 834 trucks per typical weekday 

(less on weekends) (1668 round trips), which is less than 

1.5 percent of EPA’s guidance for total AADT for 

particulate matter and less than 1.2 percent of FHWA’s 

guidance for total AADT for MSATs. The particulate 

emissions from rail activity as estimated for the Memphis 

Regional IMF are not large enough to make up the 

remaining 98.5 percent of emissions associated with “air 

quality projects of concern”. Therefore, the evaluations 

presented above support the identification of the proposed 

Memphis Regional IMF as a Level 2 project that requires a 

qualitative analysis of MSATs due to the low potential 

MSAT effects. 

However, an initial quantitative evaluation of MSATs was 

completed. MSAT emissions from activities associated 

with the proposed Memphis Regional IMF operation are 

predominantly exhaust emissions from visiting 

locomotives, visiting trucks, and IMF dedicated support 

equipment. Emission factors for the acrolein, benzene, 

1,3-butadiene, formaldehyde, naphthalene, and POM can 

be calculated by the EPA’s MOBILE6.2 Vehicle Emission 

Model. In addition, this model calculates DPM emission 

factors which are classified by sulfate, organic carbon, and 

elemental carbon fractions. These emission factors were 

used in conjunction with available operation information for 

 

128 EPA and FHWA 2006. 

129 FHWA 2009. 
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the proposed Memphis Regional IMF to estimate MSAT 

emissions for these compounds from tractor trailers (i.e., 

the container trucks), on-site maintenance trucks, and 

employee vehicles. 

In addition, DPM emissions for locomotives and non-road 

support equipment including cranes, sideloaders, and 

hostler trucks were estimated using the EPA’s Emission 

Factors for Locomotives130 and the EPA’s 

NONROAD2008a Emission Model131, respectively. 

Emission factors for the individual MSAT compounds are 

not readily available for the nonroad sources, i.e., the IMF 

yard equipment and locomotives. To estimate individual 

MSAT emissions from these sources, a conservative 

approach was applied. This approach assumes the 

individual MSAT compounds are emitted in association 

with the VOC fraction of diesel combustion products from 

on-road mobile sources. A ratio of VOC emissions from 

the on-road mobile sources (i.e., container and trailer 

trucks, maintenance trucks, and employee vehicles) to the 

nonroad sources (locomotives and yard equipment) was 

calculated and then this ratio was applied to the individual 

MSAT emissions for mobile sources to allow for an 

estimation of emissions for the nonroad equipment and 

locomotives. Such an approach has historically been used 

by states for SIP preparation purposes at the county-wide 

emissions level. Given that specific projects like MRIMF 

use specific truck types that are not representative of the 

distribution of truck types across the county, this approach 

may not be reflective of actual MSAT emissions from 

nonroad equipment and is expected to be conservative 

due to the large heavy-duty trucks that factor into the 

calculation of the ratio. 

A review of potential MSAT emissions indicates that the 

proposed project is expected to be associated with higher 

levels of MSAT emissions in the local study area during 

facility operation, relative to the No-Build Alternative. The 

conservative evaluation of MSAT emissions indicates, 

however, that the increase in the emissions associated 

with the five individual MSATs and POM is relatively small 

with less than 1.4 tpy being emitted in Fayette County, and 

less than 0.02 tpy in Marshall County. DPM emissions 

associated with the proposed IMF are estimated at less 

than 8 tpy in Fayette County, and less than 0.1 tpy in 

Marshall County. 

 

130 EPA, Emission Factors for Locomotives, Office of Transportation and Air 

Quality, EPA-420-F-09-025, April 2009. 

131 EPA, NONROAD2008a, Emission Inventory Model posted July 2009, 

http://www.epa.gov/oms/nonrdmdl.htm#mo. 
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It should be noted that NSR has committed to the use of 

Tier 4 technology in the overhead lift cranes at the 

proposed Memphis Regional IMF. Emissions, however, 

were conservatively estimated assuming Tier 3 technology. 

As noted previously, on a regional basis, EPA mandated 

vehicle and fuel regulations in combination with fleet 

turnover are expected to result in significant reductions in 

MSAT emissions. According to an FHWA analysis using 

EPA's MOBILE6.2 model, even if vehicle activity (vehiclemiles traveled [VMT]) increases by 145%, a combined 

reduction of 72% in the total annual emission rate for the 

priority MSAT is projected from 1999 to 2050.132

Construction-related MSAT emissions are not anticipated 

to be substantial for this project as construction is not 

planned to occur over an extended building period. 

However, construction activity may generate temporary 

increases in MSAT emissions in the project area. 

As outlined by FHWA for Transportation & Toxic Air 

Pollutants in Appendix C, the following is the Prototype 

Language for Compliance with 40 CFR 1502.22 for 

Incomplete or Unavailable Information for Project-Specific 

MSAT Health Impacts Analysis.133 In FHWA's view, 

information is incomplete or unavailable to credibly predict 

the project-specific health impacts due to changes in 

MSAT emissions associated with a proposed set of 

alternatives. The outcome of such an assessment, 

adverse or not, would be influenced more by the 

uncertainty introduced into the process through 

assumption and speculation rather than any genuine 

insight into the actual health impacts directly attributable to 

MSAT exposure 

The U.S. Environmental Protection Agency (EPA) is 

responsible for protecting the public health and welfare 

from any known or anticipated effect of an air pollutant. 

They are the lead authority for administering the Clean Air 

Act and its amendments and have specific statutory 

obligations with respect to hazardous air pollutants and 

MSAT. The EPA is in the continual process of assessing 

human health effects, exposures, and risks posed by air 

pollutants. They maintain Integrated Risk Information 

System (IRIS), which is "a compilation of electronic reports 

on specific substances found in the environment and their 

potential to cause human health effects".134 Each report 

 

132 FHWA MSAT Guidance September 30, 2009. 

133 FHWA 2009. 

134 EPA, http://www.epa.gov/ncea/iris/index.html
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contains assessments of non-cancerous and cancerous 

effects for individual compounds and quantitative estimates 

of risk levels from lifetime oral and inhalation exposures 

with uncertainty spanning perhaps an order of magnitude. 

Other organizations are also active in the research and 

analyses of the human health effects of MSAT, including 

the Health Effects Institute (HEI).135 Two HEI studies are 

summarized in Appendix D of FHWA's Interim Guidance 

Update on Mobile Source Air Toxic Analysis in NEPA 

Documents. Among the adverse health effects linked to 

MSAT compounds at high exposures are cancer in 

humans in occupational settings; cancer in animals; and 

irritation to the respiratory tract, including the exacerbation 

of asthma. Less obvious is the adverse human health 

effects of MSAT compounds at current environmental 

concentrations136 or in the future as vehicle emissions 

substantially decrease.137

The methodologies for forecasting health impacts include 

emissions modeling; dispersion modeling; exposure 

modeling; and then final determination of health impacts - 

each step in the process building on the model predictions 

obtained in the previous step. All are encumbered by 

technical shortcomings or uncertain science that prevents 

a more complete differentiation of the MSAT health 

impacts among a set of project alternatives. These 

difficulties are magnified for lifetime (i.e., 70 year) 

assessments, particularly because unsupportable 

assumptions would have to be made regarding changes in 

travel patterns and vehicle technology (which affects 

emissions rates) over that time frame, since such 

information is unavailable. The results produced by the 

EPA's MOBILE6.2 model, the California EPA's Emfac2007 

model, and the EPA's DraftMOVES2009 model in 

forecasting MSAT emissions are highly inconsistent. 

Indications from the development of the MOVES model are 

that MOBILE6.2 significantly underestimates diesel 

particulate matter (PM) emissions and significantly 

overestimates benzene emissions. 

Regarding air dispersion modeling, an extensive 

evaluation of EPA's guideline CAL3QHC model was 

conducted in a National Cooperative Highway Research 

Program (NCHRP) study138, which documents poor model 

 

135 HEI is a nonprofit corporation chartered in 1980 as an independent research organization to provide science on the 

health effects of air pollution. Although HEI receives government funding, it is not a regulatory body for the purpose of 

development of applicable requirements under the CAA. 

136 HEI, http://pubs.healtheffects.org/view.php?id=282

137 HEI, http://pubs.healtheffects.org/view.php?id=306) 

138 http://www.epa.gov/scram001/dispersion_alt.htm#hyroad
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performance at ten sites across the country - three where 

intensive monitoring was conducted plus an additional 

seven with less intensive monitoring. The study indicates 

a bias of the CAL3QHC model to overestimate 

concentrations near highly congested intersections and 

underestimate concentrations near uncongested 

intersections.139 The consequence of this is a tendency to 

overstate the air quality benefits of mitigating congestion at 

intersections. Such poor model performance is less 

difficult to manage for demonstrating compliance with 

National Ambient Air Quality Standards for relatively short 

time frames than it is for forecasting individual exposure 

over an entire lifetime, especially given that some 

information needed for estimating 70-year lifetime 

exposure is unavailable. It is particularly difficult to reliably 

forecast MSAT exposure near roadways, and to determine 

the portion of time that people are actually exposed at a 

specific location. 

There are considerable uncertainties associated with the 

existing estimates of toxicity of the various MSAT, because 

of factors such as low-dose extrapolation and translation of 

occupational exposure data to the general population, a 

concern expressed by HEI.140 As a result, there is no 

national consensus on air dose-response values assumed 

to protect the public health and welfare for MSAT 

compounds, and in particular for diesel PM. The EPA141

and the HE142 have not established a basis for quantitative 

risk assessment of diesel PM in ambient settings. 

There is also the lack of a national consensus on an 

acceptable level of risk. The current context is the process 

used by the EPA as provided by the Clean Air Act to 

determine whether more stringent controls are required in 

order to provide an ample margin of safety to protect public 

health or to prevent an adverse environmental effect for 

industrial sources subject to the maximum achievable 

control technology standards, such as benzene emissions 

from refineries. The decision framework is a two-step 

process. The first step requires EPA to determine a "safe" 

or "acceptable" level of risk due to emissions from a 

source, which is generally no greater than approximately 

100 in a million. Additional factors are considered in the 

second step, the goal of which is to maximize the number 

of people with risks less than 1 in a million due to 

 

139 Modeling methods and criteria established in other jurisdictions would not be applicable to the Memphis Regional 

IMF. This information is being provided only in the context of describing the inconsistency and uncertainty of methods 

and approaches to MSAT analysis as specified in FHWA guidance at FHWA 2009. 

140 http://pubs.healtheffects.org/view.php?id=282

141 http://www.epa.gov/risk/basicinformation.htm#g

142 http://pubs.healtheffects.org/getfile.php?u=395
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emissions from a source. The results of this statutory twostep process do not guarantee that cancer risks from 

exposure to air toxics are less than 1 in a million; in some 

cases, the residual risk determination could result in 

maximum individual cancer risks that are as high as 

approximately 100 in a million. In a June 2008 decision, 

the U.S. Court of Appeals for the District of Columbia 

Circuit upheld EPA's approach to addressing risk in its two 

step decision framework. Information is incomplete or 

unavailable to establish that even the largest of highway 

projects would result in levels of risk greater than safe or 

acceptable. 

Because of the limitations in the methodologies for 

forecasting health impacts described, any predicted 

difference in health impacts between alternatives is likely 

to be much smaller than the uncertainties associated with 

predicting the impacts. Consequently, the results of such 

assessments would not be useful to decision makers, who 

would need to weigh this information against project 

benefits, such as reducing traffic congestion, accident 

rates, and fatalities plus improved access for emergency 

response, that are better suited for quantitative analysis. 

Although as discussed above the uncertainties and 

limitations in methodologies for assessing MSATs and their 

effects are significant, the qualitative analysis of MSAT 

emissions for the MRIMF indicates that the increase in 

MSAT emissions, which would be experienced only locally 

and offset by the removal of 186 million vehicle miles per 

year of loaded truck travel, amounts to a less than 1.4 tpy 

being emitted in Fayette County, and less than 0.02 tpy in 

Marshall County. DPM emissions associated with the 

proposed IMF are estimated at less than 8 tpy in Fayette 

County, and less than 0.1 tpy in Marshall County. These 

projections utilized Tier 3 technology emissions, not Tier 4 

which would be phased in for the facility as a mitigation 

measure, and does not include the future reductions in 

MSATs anticipated by EPA’s mandated vehicle and fuel 

regulations which project a significant decrease in MSATs 

– a 72% reduction by 2050 even if vehicle miles traveled 

increased by 145%. Accordingly, MSAT emissions 

resulting from the MRIMF would not be considered to have 

a substantial effect on air quality. 

3.7.4 Air Quality Impacts 

The operation of the proposed IMF would result in a minor 

increase in the emission of criteria air pollutants and 

MSATs in the Fayette and Marshall Counties, primarily 

through the operation of mobile sources. The primary 

purpose of the proposed Memphis Regional IMF is to meet 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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demand for intermodal (rail/truck) transportation in the 

Memphis region. An advantage of the project is that the 

future highway truck traffic between Memphis and the 

Northeast would be reduced by an estimated 186 million 

loaded truck vehicle miles per year.143 Ultimately, the 

increased rail usage would remove long-haul trucks from 

highways reducing congestion with an added benefit of 

increased safety and air quality, including a decrease in 

GHG emissions of carbon dioxide by approximately 

264,000 tons annually.144 

Therefore, although the project would cause a minor 

localized increase in the emissions of criteria air pollutants 

and MSATs, it is expected to have no adverse impacts on 

air quality in the area. 

The No-Build Alternative would have no localized air 

quality affect. However, with the No-Build alternative, 

trucks would continue to carry freight in the region and 

nationally and therefore, emissions of criteria air pollutants 

and other emissions would not be reduced. 

3.7.5 Greenhouse Gas Emissions/Climate Change 

The GHG emissions are gases in the Earth’s atmosphere 

that absorb and emit radiation within the thermal infrared 

range. The main greenhouse gases in the Earth’s 

atmosphere are water vapor, carbon dioxide, methane, 

nitrous oxide, and ozone. This process is the fundamental 

cause of the greenhouse effect. The EPA has recently 

issued an endangerment finding for GHG emissions 

indicating that elevated concentrations of GHGs in the 

atmosphere may reasonably be anticipated to endanger 

the public health and to endanger the public welfare. 

Carbon dioxide is expected to remain the dominant 

anthropogenic GHG.145

The GHG emissions are directly related to fuel 

consumption. Because railroads are approximately three 

and a half times more fuel efficient than trucks on a tonmile basis, shipment of freight by rail has been shown to 

result in a corresponding decrease in carbon and other 

emissions.146 Given that the Memphis Regional IMF 

would transfer an estimated 327,000 containers and 

trailers per year through the facility, there would be a 

substantial reduction in carbon dioxide and other 

emissions. 

 

143 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 

144 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 

145 Federal Register Volume 74, No. 239, pages 66496-66546, December 15, 2009. 

146 AAR, November 2009. 
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Further indirect and cumulative impacts associated with air 

quality and GHGs are discussed in Section 3.18.12.2. 

3.8. Noise Impacts 

Noise guidelines and regulations have been established to 

protect citizens from potential hearing damage and various 

other adverse physiological, psychological, and social 

effects associated with noise. “Noise” is generally defined 

as unwanted sound. Under NEPA, the Noise Control Act 

of 1972 (NCA)147 and EO 12088: Federal Compliance with 

Pollution Control Standards, DOT, MDOT, and TDOT must 

assess the environmental impact of noise produced by the 

Memphis Regional IMF. Fayette County, Tennessee, 

Marshall County, Mississippi, nor the Town of Rossville 

has any applicable general noise control laws or 

regulations. 

Evaluation of noise levels generated by trains entering and 

departing the Memphis Regional IMF, container and trailer 

transfer related equipment operations, and truck traffic 

entering and departing the facility are included in the 

analysis, along with potential impacts thereof. To more 

accurately predict noise levels from each of the activities 

mentioned above and the overall Memphis Regional IMF 

noise impacts, multiple methodologies are used. 

For rail- and facility-related noise, the analysis is in 

accordance with the Federal Transit Administration (FTA) 

Transit Noise and Vibration Impact Assessment 

Manual.148 Both the FTA and the FRA use this manual for 

evaluating rail-related noise. 

 

The roadway portions of the noise analysis have been 

prepared in accordance with the Procedures for Abatement 

of Highway Traffic and Construction Noise, 23 C.F.R. 

772149 and the Highway Traffic Noise Analysis and 

Abatement Policy and Guidance.150 The evaluation also 

followed the MDOT Highway Traffic Noise Policy)151, the 

TDOT Policy on Highway Traffic Noise Abatement152, and 

additional noise analysis guidance from TDOT personnel. 

For rail- and facility-related noise, the analysis is in 

accordance with the Federal Transit Administration (FTA) 

Transit Noise and Vibration Impact Assessment 

 

t seq. 

.R. 772. 

way Traffic Noise Abatement, September 2005. 

147 42 U.S.C. 4901 e

148 FTA, May 2006. 

149 FHWA, 23 C.F

150 FHWA, 1995. 

151 MDOT, 1996. 

152 TDOT, Policy on High
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Manual.153 Both the FTA and the FRA use this manual for 

evaluating rail-related noise. 

3.8.1 Fundamentals of Sound and Noise 

The intensity or loudness of sound is measured in units 

called decibels (dB). However, since the human ear does 

not hear sound waves of different frequencies at the same 

subjective loudness, an adjustment or weighting of the 

high-pitched and low-pitched sounds is made to 

approximate how an average person hears sounds. When 

such adjustments to the sound levels are made, they are 

called “A-weighted levels” and are usually labeled “dBA.” 

A noise level change of 3 dBA is barely perceptible to 

average human hearing, whereas a 5 dBA change in noise 

level is noticeable. A 10 dBA increase in noise level is 

perceived as doubling of noise loudness. 

To provide a context to compare the magnitude of noise 

levels discussed in this analysis, Table 3-9 presents some 

common A-weighted noise levels. 

Because most environmental noise fluctuates from 

moment to moment, it is standard practice to condense 

data into a single level called the equivalent sound level 

(Leq). The Leq is a steady sound level that would contain 

the same amount of sound energy as the actual timevarying sound evaluated over the same time-period. The 

Leq uses weighted averaging of the louder and quieter 

moments, giving much more weight to the louder 

moments. For highway traffic noise assessment purposes,

the FHWA and TDOT use Leq to evaluate the peak onehour period of the day and it is defined as Leq(1h). 

The FTA/FRA use another metric to quantify the noise 

environment: the Day-Night Sound Level (Ldn). The Ldn 

averages continuous noise, such as a busy transit corridor, 

and provides a measure of total sound energy over a 24-

hour period. When determining Ldn over the course of a 

24-hour day, a 10 dBA penalty is applied to noise levels 

generated during night-time hours (10 p.m. to 7 a.m.). 

Thus, Ldn effectively identifies a “noise dose” for a day. 

Scientific studies and social surveys have found Ldn to be a 

good measure for assessing levels of annoyance 

associated with all types of environmental noise. 

 

153 FTA, May 2006. 
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Table 3-9: Typical Sound Levels Measured in the E nt and Industry nvironme

Source Noise Level 

[ dBA] Comment 

Shotgun (at shooter’s ear); Carrier flight ainfully Loud deck. 140 P

Civil Defense Siren (100 ft away) 130 

Jet takeoff (200 feet away) 120 Threshold of Pain 

Loud rock music; rock music concert 110 

Pile driver (50 feet away) 100 Very loud

Ambulance siren (100 ft away); Boiler room. 90 

Pneumatic drill (50 ft); Noisy restaurant. 80 

Busy traffic; Hair dryer; Freeway traffic. 70 Intrusive 

Normal conversation (5 feet); Data 

processing center. 60 

Light traffic (100 ft); Rainfall; Typical 

suburban background. 50 Quiet 

Bird calls (distant); Average living room; 

Library 40 

Soft whisper (5 feet); Quiet bedroom. 30 

Recording Studio 20 

Normal breathing; Rustling leaves 10 Threshold of hearing 

Source: Beranek, 1998; City of Brentwood, CA General; P

Sound intensity attenuates as it travels away from the 

source in accordance with principles called geometrical 

spreading. The standard rule-of-thumb for the attenuation 

of sound from geometrical spreading for line sources (e.g., 

vehicles passing along a roadway or trains on a railway) is 

the reduction of 3 dBA per doubling of distance length, 

beginning at 50 feet from the noise source. Sounds from 

point sources (i.e., cranes, yard areas, which do not move 

over large areas) attenuate approximately 6 dBA for every 

doubling of the distance. Additional attenuation of sound 

occurs due to a phenomenon of ground absorption of 

sound energy if the ground type is soft, such as a grassy 

field or forest. Geometrical spreading and ground 

absorption p

lan, March 2009. 

ropagation are defined mathematically in the 

FTA Transit Noise and Vibration Impact Assessment

 

Manual.154 

Additional environmental attenuation of sound may be 

provided by the presence of natural or man-made sound 

barriers. Natural sound barriers include topographical 

154 FTA, May 2006. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-63 

6/30/2010 

features separating noise sources from receiver locations. 

The term insertion loss (IL) is used to describe the 

reduction in Leq when a noise barrier is constructed or a 

topographical feature (e.g., ridgeline) exists which blocks 

the line-of-sight between the noise source and the 

receiver. For example, if the Leq at a point is 75 dBA and 

the Leq after a barrier is constructed is 65 dBA, then the IL 

would be 10 dBA. An effective noise barrier or 

topographical feature has an IL of 10 to 15 dBA, which 

reduces the perceived noise of a source by half. These 

shielding characteristics are defined mathematically in 

Section 6.3.2 of the FTA Transit Noise and Vibration 

nditions in the environment, 

these factors are often not considered for purposes of 

or 

exceeds the Noise Abatement Criteria (NAC) listed for 

as Activity Category B, or exterior areas 

of residences and churches, are considered to be sensitive 

nd use areas. 

 

Impact Assessment Manual.155

Additional environmental attenuation of sound can be 

provided by atmospheric conditions and the presence of 

dense vegetation. However, due to the variability of 

atmospheric and vegetation co

community noise evaluations. 

3.8.2 Criteria for Determining Impacts 

The FHWA noise standards,156 MDOT noise policy, and 

TDOT noise policy each provide that traffic-related noise 

impacts that warrant consideration of abatement occur 

when peak-hour Leq(1h) approaches (within 1 dBA) 

various land use or activity categories in Table 3-10.157 

TDOT’s noise abatement policy158 defines “approach” as 

within one decibel (1 dBA) below the NAC. The guidelines 

also state that noise mitigation should be considered for 

any receptors where predicted traffic noise levels for future 

conditions are greater than existing noise levels by 10 dBA 

or more when future noise levels are between 57 and 67 

dBA. For purposes of evaluating potential noise impacts 

associated with the Memphis Regional IMF, those 

receptors defined 

la

155 FTA, May 2006. 

156 23 CFR 772. 

157 Policy on Highway Traffic Noise Abatement, Tennessee Department of Transportation Policy No. 520-01, September 

2005. 

158 TDOT, September 2005. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-64 

6/30/2010 

Table 3-10: FHWA/TDOT Noise Abatement Criteria for Traffic Noise Impacts 

Activity 

Category Leq(h) (dBA) Description of Activity 

A 57 (Exterior) 

Land on which serenity and quiet are of extraordinary 

significance and serve an important public need and 

where the preservation of those qualities is essential if 

the area is to continue to serve its intended purpose. 

B 67 (Exterior) 

Picnic areas, recreation areas, playgrounds, active 

sports areas, parks, residences, motels, hotels, schools, 

churches, libraries, and hospitals. 

C 72 (Exterior) Developed lands, properties, or activities not included in 

Categories A or B above. 

D --- Undeveloped lands. 

E 52 (Interior) Residences, motels, hotels, public meeting rooms, 

schools, churches, libraries, hospitals, and auditoriums. 

Source: TDOT, Policy on Highway Traffic Noise Abatement, 2005. 

Table 3-11 presents the TDOT criteria used to define the 

severity of impacts due to noise increases associated with 

the proposed project, when the future sound level is 

between 57 and 67 dBA.159

These criteria are established by the U.S. Department of 

Transportation (FHWA/FRA/FTA), TDOT, and MDOT. 

Note that The MDOT’s Highway Traffic Noise Policy

mirrors TDOT’s criteria, except MDOT’s definition of a 

traffic noise impact differs in that a substantial increase 

between future project-related and existing Leq(1h) is defined 

as an increase of 15 dBA instead of 10 dBA.160 Therefore, 

compliance with the 10 dBA increase criteria meets both 

the TDOT and MDOT policies. 

Table 3-11: Criteria to Define Impacts Due to Traffic Noise Increases 

Increase in Existing Noise Levels (dBA) Subjective Descriptor 

0 – 5 Minor Increase 

6 – 9 Moderate Increase 

10 or more Substantial Increase 

Source: TDOT, Policy on Highway Traffic Noise Abatement, 2005. 

Potential impacts associated with rail components of this 

project were evaluated according to Chapter 3 of the FTA 

Transit Noise and Vibration Impact Assessment Manual. 

 

159 TDOT, September 2005. 

160 MDOT, 1996. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-65 

6/30/2010 

Land use category descriptions and associated noise 

metrics for rail-related noise impacts are summarized in 

Table 3-12.161

Table 3-12: FTA Land Use Categories and Metrics for Rail Noise Impact Criteria 

Land Use 

Category

Noise Metric 

(dBA)

Description of Land Use Category

1 Outdoor Leq(h)

Tracts of land where quiet are an essential element in their 

intended purpose. This category includes lands set aside for 

serenity and quiet, and such land uses as outdoor 

amphitheaters and concert pavilions, as well as National Historic 

Landmarks with significant outdoor use. Also included are 

recording studios and concert halls.

2 Outdoor Ldn

Residences and buildings where people normally sleep. This 

category includes homes, hospitals and hotels where night-time 

sensitivity to noise is assumed to be of utmost importance.

3 Outdoor Leq(h)

Institutional land uses with primarily daytime and evening use. 

This category includes schools, libraries, theaters, and churches 

where it is important to avoid interference with such activities as 

speech, meditation and concentration on reading material. 

Places for meditation or study associated with cemeteries, 

monuments, museums, campgrounds and recreational facilities 

can also be considered to be in this category. Certain historical 

sites and parks are also included.

Source: FTA 2006

For rail transit projects potentially affecting residences 

(Land Use Category 2), predicted noise levels are 

evaluated for impacts using the Ldn descriptor. The 

‘projected noise exposure’ Ldn would be compared to the 

existing ‘nominal’ Ldn to evaluate whether impacts are 

predicted. For churches and other Category 3 land uses, 

predicted noise levels are evaluated for impacts using the 

Leq descriptor. The FTA/FRA impact criteria are shown 

graphically in Figure 3-16. 

For Build Alternative 1, noise measurements were 

conducted at several reference locations, also called 

Receivers, representing an exterior area of a cluster of 

residences. Existing sound levels were measured and/or 

predicted at Noise Receiver locations are shown on Figure 

3-17. 

 

161 Transit Noise and Vibration Impact Assessment, USDOT, Federal Transit Administration (FTA). FTA report FTAVA90-1003-06. May 2006. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-66 

6/30/2010 

Figure 3-16: FTA Impact Criteria: Graphical 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-67 

6/30/2010 

Figure 3-17: Noise Receptors Location 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-68 

6/30/2010 

3.8.2.1 Future Noise Level Analysis 

To predict future sound levels caused by the proposed 

Memphis Regional IMF, sound levels associated with 

construction, roadways, trains, and operation of cranes, 

loaders, and other equipment inside the yard area were 

determined separately. NSR developed rail and roadway 

traffic projections, as well as facility operation schedules, 

for the project for the design year 2032. Highway traffic 

noise modeling of the project area for the existing scenario 

was completed using the FHWA Traffic Noise Model 

(TNM) Version 2.5 computer program. NSR followed 

TDOT guidance on how to model the sound levels from the 

Memphis Regional IMF operating yard. This guidance 

resulted in a conservative approach whereby all IMF noise 

sources were assumed to be at the closest edge of the 

IMF operational area (where the cranes and packers would 

operate) relative to the receiver rather than at actual 

locations across the operating area(s). For example, 

cranes operating in the loading and unloading area would 

actually be more than 2,000-feet away from the western 

edge of the IMF. This approach conservatively predicts 

higher noise levels at receiver locations. A more detailed 

description of this methodology is included in the Noise 

Assessment Technical Report on file with TDOT.162 

Since most environmental noise fluctuates from moment to 

moment, it is standard practice to condense data into a 

single level called the equivalent sound level (Leq). 

Because train arrivals and departures are projected to 

occur during night-time hours, this analysis examines the 

future rail-related Ldn for Build Alternative 1. Average 

hourly Memphis Regional IMF train movements and 

operations during daytime and night-time periods were 

calculated. The guidelines in the FTA Transit Noise and 

Vibration Impact Assessment Manual163 were used to 

predict sound levels generated along the lead tracks and 

the Memphis Regional IMF yard area, and those values 

were then summed logarithmically to develop a composite 

Ldn at each identified noise receiver location. Finally, Total 

Ldn was determined by adding the composite IMF facility 

Ldn to the existing Ldn for comparison to FTA impact 

criteria. 

3.8.2.2 Noise Impact Analysis for Design Year 2032 

Based on the MDOT April 2010 request, the following 

parameters, which affect the potential noise impacts, 

increase the growth rate to 2.5% per year for background 

 

162 AMEC, December 2009. 

163 FTA, May 2006. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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6/30/2010 

(or existing) traffic volumes (instead of the 1% increase 

developed based on historical growth trends) and increase 

in design speed for US Hwy 72 as four-lane rural principal 

arterial to 70 mph (instead of the 65 mph originally 

provided).164

As demonstrated by Table 3-13, no traffic noise impacts 

were identified according to FHWA, MDOT, and TDOT 

criteria. Receiver locations selected for the noise analysis 

for the project include locations near the noise-sensitive 

land uses in the project areas. For the split columns in 

Table 3-13, first dBA number was based on a 1% per year 

growth along US Hwy 72 with a 65 mph design speed; the 

second dBA number was based on a 2.5% per year growth 

along US Hwy 72 with a 70 mph design speed. 

According to Table 3-14, one receiver, Receiver 15, 

representing 3 residences, is expected to experience an 

impact due to operations within the proposed IMF in 

accordance with FTA criteria. Six of the 17 receiver 

locations are located very near the state line or are in 

Marshall County, Mississippi. Accordingly, these land uses 

will also be evaluated in accordance with MDOT’s Highway 

Traffic Noise Policy.165

 Furthermore, it should be noted 

that these results are conservatively based on the TDOT 

modeling approach. 

As demonstrated in Tables 3-13 and 3-14, in the design 

year (2032) Ldn, Receivers 1, 2, 3, 4, 6, 7, 8, 10, 12, 13, 14, 

16, and 17 experience no or very slight increases in 

environmental noise associated with traffic or rail 

operations for the proposed facility. Any minor increases 

caused by traffic or rail operations are defined as ‘no 

impact’ in accordance with the FHWA/MDOT/TDOT and 

FTA/FRA noise impact criteria, respectively. Higher traffic 

noise levels were identified in the revised Build scenario for 

Receivers 5, 11, 12, and 13 with the 2.5% background 

traffic growth rate than those noted with the 1% growth 

rate. Noise levels for all other receiver locations were 

predicted to remain the same for either growth rate.166

Receiver 9 is predicted to experience moderate noise 

increases which do not exceed either FHWA/MDOT/TDOT 

or FTA/FRA noise abatement criteria. Receiver 9 

represents one residence in the vicinity of Industrial Road. 

The design year (2032) Leq predicted noise levels to be 8 

dBA higher than existing sound levels during the peak 

 

164 Phone call between AMEC and MDOT on April 13, 2010; MDOT ED (Kim Thurman) defined these parameters. 

165 MDOT, 1996. 

166 Noise Analysis of the Memphis Regional Intermodal Facility, AMEC, March 2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-70 

6/30/2010 

 

traffic hour as shown on Table 3-13. This increase is 

defined as ‘moderate’. According to FHWA/MDOT/TDOT 

policy, this increase does not constitute an impact. 

Likewise, this receiver is not expected to experience noise 

impacts associated with rail-related activities according to 

FTA/FRA policy.167

 Two receivers (5 and 11) representing 21 

residences located on and situated very close to 

US Hwy 72, currently exceed the NAC of 67 dBA 

due to existing traffic volumes on US Hwy 72. Both 

receivers are also expected to exceed the 

MDOT/FHWA noise abatement criteria in the Build 

2032 scenario. Leq values for these receivers are 

predicted to be approximately 1 to 2 dBA higher 

than the Existing condition and 1 to 2 dBA higher 

than the No-Build scenario as shown on Table 3-

13. This condition would exist even with increases 

in traffic volume associated with vehicles entering 

and leaving the proposed facility. These increases 

are defined as ’minor‘ in accordance with FHWA’s 

impact criteria and MDOT policy, and are not 

considered to be impacts caused by the project 

because the difference between the Build and NoBuild scenarios is less than 3 dBA. 

 Receiver 15, representing 3 Parnell Road 

residences in the vicinity of the AGS area, would 

not experience traffic noise impacts according to 

FHWA/TDOT noise impact criteria (see Table 3-

13). Future Receiver 15 noise levels, however, are 

predicted to be 12 dBA higher than existing sound 

levels due to the proposed Memphis Regional IMF, 

as shown on Table 3-14. 

According to FTA/FRA noise impact criteria, Receiver 15 

would be considered a ‘severe’ noise impact. This result 

does not include planned earthen berm construction along 

west side of facility as discussed in Section 3.8.3, which 

would reduce the noise impact. 

3.8.3 Noise Abatement Measures Evaluation 

Based on FHWA and FTA/FRA guidance and projected 

facility operations, the study has identified potential noise 

impacts to sensitive land use areas. In particular, those 

impacts are identified in the vicinity of the southwest corner 

of the Memphis Regional IMF near the AGS. Receiver 15, 

representing three residences on Parnell Road, could be 

affected by noise impacts. 

167 FTA, May 2006. 
3 ENVIRONMENTAL CONSEQUENCES OF THE 

Table 3-13: Predicted Traffic Noise Results and Summary of Traffic Noise Impacts 

Receiver Location 

No. 

FHWA 

Noise 

Abatement 

Criteria 

(NAC) 

(dBA) 

Nominal 

Existing 

2009 Leq

(dBA) 

Traffic 

Noise 

Model 

(TNM) 

Existing 

2009 WorstHour Leq 

(dBA) 

TNM NoBuild 2032 

WorstHour 

Traffic Leq

(dBA) 

TNM Build 

2032 

WorstHour 

Traffic Leq

(dBA) 

Greater of 

TNM Build 

2032 and 

Measured 

Leq (dBA)) 

 FHWA 

Traffic 

Noise 

Increase 

Caused by 

Project? 

Predicted 

Traffic Noise 

Level 

Approaches or 

Exceeds NAC?

I

C

P

Background Traffic Growth Rate 1% 2.5% 1% 2.5% 1% 2.5% 1% 2.5% (per year) 

1 67 52 34 34 35 35 37 37 52 52 None No No 2 67 49 29 29 30 32 40 40 49 49 None No No 3 67 48 35 35 36 36 38 38 48 48 None No No 4 67 52 29 29 31 32 37 38 52 52 None No No 5 67 72 71 71 72 73 73 77 73 77 Minor Yes No 6 67 71 58 58 59 59 61 61 61 61 None No No 7 67 61 41 41 42 42 43 43 52 52 None No No 8 67 48 34 34 36 37 52 52 52 52 Minor No No 9 67 48 34 34 36 37 56 56 56 56 Moderate No No 

10 67 48 34 34 36 38 49 49 49 49 Minor No No 11 67 67 68 68 69 71 69 74 69 74 Minor Yes No 12 67 52 51 51 52 54 53 56 53 56 Minor No No 13 67 52 52 52 53 55 55 58 55 58 Minor No No 14 67 46 39 39 41 42 44 45 46 46 None No No 15 67 46 31 31 33 34 45 45 46 46 None No No 16 67 46 32 32 33 35 39 39 46 46 None No No 17 67 46 35 35 37 38 47 47 47 47 Minor No No 

Memphis Regional Intermodal Facility 6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE 

Memphis Regional Intermodal Facility 6/30/2010 

Table 3-14: Predicted Rail Noise Results and Summary of Impacts 

Receiver 

Location No. 

Nominal 

Existing 

Ldn (dBA) 

Predicted 

Lead Tracks 

Ldn (dBA) 

Predicted 

2032 IMF 

Yard 

Ldn

 (dBA) 

Topography 

Line-of-Sight 

Attenuation 

Loss (dBA) 

Predicted 

2032 IMF 

Project 

Noise 

Exposure, 

Ldn (dBA) 

Predicted 

2032 Total 

IMF Noise 

Level, 

Ldn

(dBA) 

Noise 

Increase 

Caused by 

Project 

 (dBA) 

F

C

P

1 52 45 41 0 47 53 1 N2 50 45 47 -5 44 51 1 N3 51 51 42 -2.5 49 53 2 N4 52 41 52 -5 48 53 1 N5 75 27 42 0 42 75 0 N6 64 44 37 0 45 64 0 N7 52 33 34 0 37 52 0 N8 50 45 50 -5 46 51 1 N9 50 44 50 -5 46 51 1 N

10 50 43 49 -5 45 51 1 N11 71 29 43 -5 38 71 0 N12 52 28 42 -5 38 52 0 N13 52 28 42 -5 37 52 0 N14 49 29 45 -5 40 50 1 N15 49 40 60 0 60 61 12 16 49 44 39 -2.5 43 50 1 N17 49 43 48 -5 44 50 1 N
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

The FHWA, MDOT, TDOT, and FTA/FRA require that 

noise abatement measures be considered for feasibility 

and reasonableness when impacts are predicted to occur 

at sensitive land uses. 

In order to be considered feasible, noise barriers (noise 

walls or berms) should be physically possible to construct 

and should produce a 10 dBA reduction with a minimum 7 

dBA reduction in future noise levels for closest receivers 

according to TDOT Noise Abatement Policy. Because the 

available area within the facility is sufficient for construction 

of noise walls or earthen berms, noise barriers are 

considered to be a feasible option. Due to the low number 

of residences (3) associated with Receiver 15 experiencing 

the potential impacts, construction of a noise barrier in the 

location would normally be considered cost-prohibitive and 

therefore not reasonable based on TDOT’s Noise 

Abatement Policy and FTA/FRA noise mitigation guidance. 

However, due to public concerns identified during the 

NEPA process, proximity of certain residences, and 

potential future land uses in vicinity, NSR will construct 

noise barriers (earthen berms) on the proposed facility as 

follows: 1) along portions of eastern and western 

boundaries of the IMF facility and AGS area and 2) along 

portions of western side of lead tracks (Neville Road area). 

It is anticipated the proposed berms would achieve noise 

reductions of approximately 5 to 7 dBA at Receiver 15, 

reducing the impact category from ‘severe’ to ‘moderate’ 

impact at an Ldn of 6 dBA above existing Ldn. 

A berm along the lead tracks would block much of the 

sound path between receivers and trains entering and 

departing the IMF. It is estimated the proposed berm 

would achieve noise reductions of 3.5 dBA at these 

residences. 

The noise reductions provided by the proposed earthen 

berms and final anticipated noise levels at each receiver 

location are presented in Table 3-15. 

In addition, NSR would incorporate other noise reduction 

measures into the overall design to minimize noise 

impacts, including: 

Memphis Regional Intermodal Facility 3-73 

6/30/2010 
3 ENVIRO

Table 3-15: Predicted Noise Levels with Berm Installation

Receiver 

Location No. 

Nominal 

Existing Ldn

(dBA) 

Predicted 2032

IMF Noise 

Exposure Ldn

Without Berms

(dBA) 

Proposed 

Berm 

Noise 

Attenuation 

(dBA) 

Predicted 

2032 IMF 

Noise 

Exposure Ldn

With Berms, 

[dBA]

Predicted 

2032 Total IMF 

Noise, Ldn

With Berms 

(dBA) 

Noise 

Increase 

Caused by 

Project, With 

Berms 

 (dBA) 

1 52 47 0 47 53 1 2 50 44 -3.5 41 51 1 3 51 49 -3.5 46 52 1 4 52 48 -3.5 44 53 1 5 75 42 0 42 75 0 6 64 45 0 45 64 0 7 52 37 0 37 52 0 8 50 46 -3.5 42 51 1 9 50 46 -3.5 42 51 1 

10 50 45 -3.5 41 51 1 11 71 38 -3.5 35 71 0 12 52 38 -3.5 34 59 0 13 52 37 -3.5 34 59 0 14 49 40 -3.5 37 49 0 15 49 60 -7.0 53 55 6 16 49 43 -3.5 39 50 1 17 49 44 -3.5 41 50 1 

Memphis Regional Intermodal Facility 6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

 Grade crossings have been eliminated from 

the project design by creating an overpass at 

SR-57. This will eliminate train horn blowing 

that is otherwise required at such crossings. 

Horn blowing may still occur within the facility 

for emergency warning purposes. 

 Rail lines would be constructed of continuous 

welded rail (non-jointed) track with radius of 

rail curvatures ranging between 6° (Radius 

955.37’) and 8°30’ (Radius 674.69’) with the 

majority of the rail curves consisting of an 8° 

(Radius 716.78’) to minimize transient rail 

noises. 

 The horizontal and vertical alignments of the 

lead tracks are constrained by mainline 

elevations, topography and facility design 

considerations for the selected alternate. The 

facility grading plan, combined with natural 

topographic features of the project vicinity, 

provide inherent noise reductions for many of 

the area residents. Further alteration of 

horizontal and vertical alignments for noise 

abatement purposes is not feasible. 

 Rail and truck operations in the vicinity of the 

proposed facility would operate at low 

speeds, thereby keeping speed-related noise 

emissions to a minimum.

3.8.4 Design Year (2032) No-Build Alternative Noise 

Environment 

Under the No-Build Alternative, the Memphis Regional IMF 

construction and operation would not affect noise levels. 

Noise levels, however, would continue to increase in the 

project area due to vehicle traffic that is anticipated to 

occur due to planned growth in the Rossville UGB in 

Tennessee, the Chickasaw Trail Industrial Development 

(an independent development) area in Mississippi and 

along US Hwy 72 in Mississippi. 

3.9. Cultural Resource Impacts 

Cultural resources or historic properties include 

archaeological sites and architectural buildings and 

structures. Pursuant to the guidelines for Section 106 of 

the National Historic Preservation Act (NHPA), as outlined 

in 36 C.F.R. Part 800, studies were conducted to 

determine if any cultural resources exist in the project’s 

Area of Potential Effect (APE) that are listed in or eligible 

for listing on the NRHP. 

Memphis Regional Intermodal Facility 3-75 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-76 

6/30/2010 

In order to be listed or eligible for listing on the NRHP, the 

cultural resource must meet one or more of the following 

criteria: 

a) Associated with events that have made 

a significant contribution to the broad 

patterns of our history; 

b) Associated with the lives or persons 

significant in our past; 

c) Embody the distinctive characteristics of 

a type, period, or method of 

construction, or that represent the work 

of a master, or that possess high artistic 

values, or that represent a significant 

and distinguishable entity whose 

components may lack individual 

distinction; or, 

d) Have yielded, or may be likely to yield, 

information important in prehistory or 

history.168 

Based on early coordination with the Tennessee Historical 

Commission (THC), Tennessee State Historic Preservation 

Office (SHPO), the APE for historic architectural resources 

was determined to include Build Alternative 1 project site 

and a one-mile buffer area that surrounds it (Figure 3-18). 

The APE extended into Mississippi and Industrial Road is 

located partially in Mississippi. Therefore, it was 

appropriate to also coordinate with the Mississippi 

Department of Archives and History (MDAH), which serves 

as the Mississippi SHPO. The historic architectural 

resource survey examined buildings and structures within 

the APE. 

The APE for archaeological resources was limited to the 

project site (Figure 3-18). The archaeological APE was 

used to determine the archaeological field survey 

boundary. 

The NRHP Criteria of Eligibility, outlined in 36 CFR Part 

60, describe what makes a property historically 

significant.169 These criteria were used to evaluate the 

significance of the surveyed historic architectural and 

archaeological properties within the APE and to determine 

 

168 Criteria for Evaluation. 36 CFR Part 60.4. 

169 National Park Service, Criteria for Evaluation, 36 C.F.R. Part 60.4. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-77 

6/30/2010 

if such properties were eligible or potentially eligible for 

listing on the NRHP. 

3.9.1 Historic Architectural Resources 

Based on consultation with the Tennessee SHPO on 

August 27, 2009, a records search was conducted at the 

THC and the MDAH to identify any historic sites listed or 

eligible for listing on the NRHP in the APE for Build 

Alternative 1. The search revealed that no properties in 

the APE had been previously surveyed and no resources 

were listed in or previously determined eligible for the 

NRHP. In fact, no structures exist on the property except 

for a modern storage shed, which is less than 50 years 

old.

A field survey and research were then conducted to 

determine: 1) if any of the previously surveyed properties 

were NRHP-eligible; 2) if the NRHP listed resources were 

still present and still eligible and; 3) if there were any other 

individual historic architectural resources (e.g., individual 

buildings or structures, such as bridges) or historic districts 

in the project’s APE that would meet the Criteria of 

Eligibility for the NRHP. Figure 3-18 shows the APE. 

The only cultural resource identified within the APE was 

the Rossville Historic District, which is listed on the 

NRHP. Not every building within the Rossville Historic 

District is located within the APE as the APE reaches only 

the western section of the historic district. The survey 

determined that the Rossville Historic District has no 

visibility of the proposed IMF due to (1) its location 

approximately one mile from the proposed SR-57 

overpass, (2) 1.5 to 2 miles from the Memphis Regional 

IMF, (3) the height of the proposed overpass (31 feet 

higher than existing SR-57) and (4) features at the 

Memphis Regional IMF, the 70-foot light posts distributed 

over the IMF site are tallest element. Heavy forestation 

and modern development in the area, specifically the 

Kellogg Company plant located west of the Rossville 

Historic District, screen the Memphis Regional IMF site. 

No historic resources would be adversely impacted by the 

proposed IMF.170

 

170 AMEC Earth & Environmental, “Memphis Regional Intermodal Facility, Viewshed Survey,” 17 November 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Figure 3-18: Memphis Regional IMF Area of Potential Effect 

Memphis Regional Intermodal Facility 3-78 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-79 

6/30/2010 

Under the No-Build Alternative, the Memphis Regional IMF 

and the SR-57 overpass would not be constructed. 

Industrial Road would; still be constructed independently 

by the Developer. As the property has been rezoned 

industrial and is within the Rossville UGB, it is anticipated 

that the property could be developed in the future for some 

other purpose under the No-Build Alternative. The NoBuild Alternative, however, would not have an effect under 

Section 106 to historic architectural resources, since there 

would be no APE and no new construction of an IMF. 

As required by Section 106, Tennessee SHPO reviewed 

this finding and concurred with it in a letter dated February 

9, 2010, (Appendix B). 

3.9.2 Archaeological Resources 

A records search was conducted to identify archaeological 

resources within the APE that would meet the Criteria of 

Eligibility for the NRHP set forth in 36 CFR Part 60.4. No 

listed or eligible archaeological resources were identified 

within the archaeological APE.171 

Ten archaeological sites were identified within a 1.25 mile 

(2 km) record search buffer around the APE. These 

archaeological sites included 8 prehistoric sites (3 with 

historic components) and 2 historic sites. No 

determination of eligibility for the NRHP had been 

conducted for any of these 10 sites. 

A field survey during May through July 2009 recorded two 

previously undocumented archaeological sites (40FY456 

and 40FY457) within the APE. Site 40FY456 is a historic 

site in an open pasture. Artifacts included ceramics, 

container and window glass fragments, and nails. Nearly 

all of the artifacts recovered dated from after the Civil War 

period and into the early 1900s. The site likely represents 

a domestic residential structure, although no structural 

remains were identified during the survey and none were 

located on the historic maps in this area. Deed research of 

the site area could not determine the owner of the property 

during the late nineteenth century and no economic or 

ethnic information about the owners or inhabitants of the 

site could be obtained. 

Site 40FY457 is a historic archaeological site on a rise east 

of a stream that crosses the project site. The artifacts date 

from after the Civil War into the early 1900s. Artifacts 

included ceramics, container and window glass fragments, 

 

171 AMEC Earth & Environmental, “Memphis Regional Intermodal Facility, Phase 1- Archeological Report,” December 

2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-80 

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nails, a metal button, and two cartridge casings. The types 

of artifacts suggest that this was the site of a domestic 

residential structure. However, no structural remnants 

were identified during the survey and none were located 

on historic maps for this area. Deed research established 

that at least four individuals owned the property during the 

late nineteenth century. Unfortunately none of these 

names were linked to census data for the area and no 

inferences could be made regarding the family size, 

ethnicity or economic status of the inhabitants. 

All artifacts from both 40FY456 and 40FY457 were 

recovered from the upper soil layers (approximately down 

to 20 inches)(plowzone of former agricultural fields) and no 

evidence of intact cultural deposits at deeper depths was 

noted. Due to the lack of intact subsurface archaeological 

deposits or foundation remnants, the degree of plowzone 

disturbance in the site areas, and the gaps in the archival 

record, Sites 40FY456 and 40FY457 were not 

recommended as eligible for inclusion on the NRHP and 

no further archaeological investigations were 

recommended. 

No sites were identified in the area of the lead tracks or the 

proposed SR-57 overpass area. 

Since there are no listed or eligible archaeological 

resources within the APE, the proposed project would have 

no effect to archaeological resources under Section 106. 

As there would be no construction of a new IMF, the NoBuild Alternative would not have effect under Section 106 

to archaeological resources.

The Tennessee SHPO concurred in a letter dated January 

28, 2010, that no adverse findings regarding eligibility and 

effects to archaeological resources (Appendix B). 

3.9.3 Section 106 Coordination 

This project has been coordinated with appropriate parties 

pursuant to Section 106 of the NHPA.172 

During the initial coordination phase, TDOT coordinated 

with local government and Native American (American 

Indian) tribes. On September 29, 2009, letters were sent 

to City of Rossville and Fayette County Mayors. On 

October 13, 2009, letters were sent to tribal 

representatives. Coordination letters were sent to the 

following Native American Tribes pursuant to Section 106:

 

172 Advisory Council on Historic Preservation, 36 CFR Part 800.2.
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

 Alabama-Quassarte Tribal Town 

 The Chickasaw Nation 

 Choctaw Nation of Oklahoma 

 Eastern Band of Cherokee Indians 

 Eastern Shawnee Tribe of Oklahoma 

 Jena Band of Choctaw Indians 

 Kialegee Tribal Town 

 Mississippi Band of Choctaw Indians 

 Muscogee (Creek) Nation 

 Poarch Band of Creek Indians 

 Quapaw Tribe of Oklahoma 

 Shawnee Tribe 

 Thlopthlocco Tribal Town 

 Tunica-Biloxi Indians of Louisiana, Inc 

 United Keetoowah Band of Cherokee Indians 

TDOT received no responses from interested parties and 

received no responses from tribes. A copy of the TDOT 

letters sent to the Native American tribes is included in 

Appendix B. On June 30, 2010,, the FRA also sent letters 

to the above listed Native American tribes. If any tribes 

express interest in the project area, they would be invited 

by FRA to become a consulting party regarding the tribe’s 

area(s) of concern and the project. 

The Phase I – Archaeological Survey and Architectural and 

Historic Survey have been submitted to the Tennessee 

SHPO for concurrence. Coordination with the Tennessee 

SHPO and the Mississippi SHPO was initiated on June 25, 

2009 and September 18, 2009, respectively. A meeting 

was held with the Tennessee SHPO on August 27, 2009 to 

discuss the appropriate APE for the historic architectural 

survey. Correspondences with the Tennessee and 

Mississippi SHPOs are included in Appendix B. 

Memphis Regional Intermodal Facility 3-81 

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3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-82 

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3.10. Recreational Resource Impacts 

Section 6(f) of the Land and Water Conservation Act of 

1965 establishes the Land and Water Conservation Fund 

(LWCF) to assist Local, State, and Federal agencies in 

meeting the demand for present and future outdoor 

recreation sites, through grants for land acquisition, park 

amenities, and other park development costs.173 Once a 

city, county, or agency has used Section 6(f) for funds, 

either the land or the park appurtenances cannot be 

eliminated or acquired without coordination with the 

Department of Interior and mitigation that replaces the 

eliminated items. 

No outdoor recreational land and water areas or facilities 

were identified as being established from grants-in-aid 

from the LWCF in the project area. Therefore, a Section 

6(f) evaluation is not required for this project. The No-Build 

and Build Alternative 1 will not involve or impact any 

recreational resources or property developed using Land 

and Water Conservation Act (Section 6(f)) funds. 

3.11. Section 4(f) 

Section 4(f) of the Department of Transportation Act of 

1966 requires an evaluation if a transportation project uses 

publicly owned land (park, recreation area, and wildlife and 

waterfowl refuge) and/or a publicly/privately owned historic 

site.174 A “use” occurs when (1) land from a Section 4(f) 

site is acquired for a transportation project, (2) there is an 

occupancy of land that is adverse in terms of the statute's 

preservationist purposes, or (3) the proximity impacts of 

the transportation project on the Section 4(f) sites, without 

acquisition of land, are so great that the purposes for 

which the Section 4(f) site exists are significantly impaired 

(normally referred to as a constructive use). 

No Public Park, recreation land, wildlife refuge, or historic 

or archaeological site listed or eligible for listing on the 

NRHP was identified in the project area. The analysis 

revealed that the No-Build and Build Alternative 1 will not 

involve or impact any Section 4(f) resources. 

3.12. Natural Resources Impacts 

The ecology study prepared for Build Alternate 1 is 

summarized below. The project is within the Coastal Plain 

physiographic unit and the Wolf River watershed 

 

173 16 U.S.C. 4601. 

174 49 U.S.C. 303. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-83 

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(Hydrologic Unit Code [HUC] 08010210).175 Ecological 

resources described in the text are shown in Figure 3-19. 

3.12.1 Terrestrial Resources 

Based on site reconnaissance, much of the project area 

has been cleared and converted to pasture. The site 

appears to have been used for agricultural purposes and 

possibly timbering within the past century. This inferred 

past disturbance is supported by the environmental 

assessment and archaeological reviews.176 Presently, 

much of the land is forested or in shrub/scrub thickets. 

Some habitats are in earlier stages of succession. The 

balance of the land is pasture. Land use in the vicinity of 

the site includes forest, pasture, and rural residential 

areas. 

Over 70% of the immediately surrounding area consists of 

agricultural and pasture lands.177 Forested areas, which 

cover less than approximately 30% of the surrounding 

area, are sporadic and primarily occur along drainages.178 

Residential development is relatively sparse; 

approximately 55 residences are located within 1/2 mile of 

the project area. There are no naturally occurring glades, 

old growth forests, or other unique habitats within the 

project boundary.

Plant communities found in the area are characteristic of 

communities formed over loess deposits. Different plant 

communities may develop on different topographic land 

forms and at different elevations. The upland forested 

communities are dominated by various oaks (i.e., white 

oak [Quercus alba], southern red oak [Q. falcata], post oak 

[Q. stellata], and black oak [Q. velutina]) and other 

hardwoods including sweetgum (Liquidambar styraciflua), 

yellow-poplar (Liriodendron tulipifera), black locust 

(Robinia pseudoacacia), black cherry (Prunus serotina), 

and slippery elm (Ulmus rubra). River birch (Betula nigra), 

American sycamore (Platanus occidentalis), red maple 

(Acer rubrum), box elder (Acer negundo), and green ash 

(Fraxinus pennsylvanica) are common along drainages 

and in floodplain areas.179 

 

175 Miller, R. A., 1974, The geologic history of Tennessee. Tennessee Div. Geol. Bull. No. 74. 36pp. 1974. 

176 AMEC, “Phase I – Archeological Survey, Proposed Memphis Regional IMF, near Rossville, Fayette County, 

Tennessee,” December 2009, and AMEC, “Phase I -ESA, Proposed Memphis Regional IMF, near Rossville, Fayette 

County, Tennessee” November 2009. 

177 Visual estimates based on 2009 Imagery from Google Maps. 

178 Visual estimates based on 2009 Imagery from Google Maps. Supported by FWS, November 2007, Forest Inventory & 

Analysis Factsheet Tennessee 2004. 

179 USDA, “The Plants Database,” 28 Dec 2009 http://plants.usda.gov. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Figure 3-19: Wetlands and Aquatic Resource Locations 

Memphis Regional Intermodal Facility 3-84 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-85 

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Open field habitats are dominated by various grasses. 

Both upland and floodplain forested habitats provide food, 

cover, and nesting opportunities for numerous small 

mammals, including rabbits, squirrels, and other rodents, 

as well as numerous reptiles, native birds, spiders and 

other arachnids, and insects. 

Common wildlife species in this area include: white-tailed 

deer (Odocoileus virginiana), raccoon (Procyon 

lotor), eastern cottontail (Sylvilagus floridanus), eastern 

gray squirrel (Sciurus carolinensis), beaver (Castor 

canadensis), muskrat (Ondatra zibethicus), bobcat (Lynx 

rufus),180 songbirds, songbirds, osprey (Pandion 

haliaetus), wild turkey (Meleagris gallopavo) , ruffed 

grouse (Bonasa umbellus), owls, waterfowl, egrets, and 

various species of toads, frogs, snakes, and turtles. 

Specific species that have been observed on-site include: 

raccoon, white-tailed deer, beaver, Eastern box turtle 

(Terrapene carolina), American robin (Turdus 

migratorius), American crow (Corvus brachyrhynchos) 

redwing blackbird (Agelaius phoeniceus) , gray catbird 

(Dumetella carolinensis), blue jay (Cyanocitta cristata), 

mourning dove (Zenaida macroura), eastern wood pewee 

(Contopus virens) , field sparrow (Spizella pusilla) , 

grasshopper sparrow (Ammodramus 

savannarum) , eastern meadowlark (Sturnella magna), 

wild turkey, turkey vulture (Cathartes aura), European 

starlings (Sturnus vulgaris) , indigo bunting (Passerina 

cyanea) , mocking bird (Mimus polyglottos), mallard 

ducks (Anas platyrhynchos), Canada geese (Branta 

canadensis), great blue heron (Ardea herodias), green 

heron (Butorides virescens), downy woodpecker 

(Picoides pubescens), and belted kingfisher (Ceryle 

alcyon).181

Several streams and ponds occur on-site, which likely 

provide habitat for various small fish as well as crayfish 

and aquatic insects. However, no essential fish habitat or 

fisheries of special concern occur on-site. No trout 

streams occur on-site. 

Short-term impacts to the area’s habitat would consist of 

dust, noise and changes in land use. Long-term impacts 

would consist of permanent loss of open and small 

wooded tracts as a result of the additional right-of-way 

(ROW) needed. In addition, construction and earthmoving 

activities would create disturbed soil areas potentially 

susceptible to invasive exotic plant species. While these 

 

180 Wildlife North America, http://www.wildlifenorthamerica.com/A-Z/Mammal/common.html.

181 The Cornell Lab of Ornithology “All About Birds,” http://www.allaboutbirds.org/guide/search. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-86 

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impacts would decrease the total area of terrestrial habitat 

within the project area, these impacts are not expected to 

be substantial.

One of the larger habitat impacts includes the loss of 

approximately 244 acres of forested habitat and 206 acres 

of non-forested habitat within the 650 acre site, as well as 

the loss of stream habitat.182 The losses would be less as 

the facility footprint is defined during design and impacts to 

habitat are avoided or minimized as practicable. The 

estimated disturbed area for the facility is 380 acres with 

the portion of forested and scrub-shrub habitat similar to 

the entire property boundary. The disturbed area would 

eliminate habitat for local fauna that currently utilize the 

site. 

To avoid impacting forested habitat, NSR designed the 

facility to avoid streams where possible and minimize 

impacts to the riparian corridors within the footprint of the 

facility. The forested habitat within the property boundary 

is mainly located along streams and around wetlands. 

NSR would maintain a 50-foot buffer where possible along 

streams that do not require direct impacts to the stream 

channel. As discussed below, NSR would also use 

retaining walls (or similar structure) to reduce impacts to 

the stream meanders, floodplain and forested riparian 

areas. 

Stream 6 is a tributary of the Wolf River that flows through 

the southern part of the site and along the western edge of 

the project site. The original design would have impacted 

several hundred feet of Stream 6 along its western 

boundary, requiring relocation and fill of the existing 

waterbody. To avoid impacting the floodplain and riparian 

forest along this portion of Stream 6, as well as potentially 

relocating several hundred feet of Stream 6, NSR shifted 

the facility footprint east of Stream 6. Shifting the facility to 

the east moved the majority of the facility footprint out of 

the Stream 6 Zone A floodplain and reduced impacts or 

disturbance to forested areas along Stream 6. The 

construction plans would designate the area along Stream 

6 as not to be disturbed for as wide of an area as possible, 

while still allowing for construction of the facility. All of the 

area outside of the facility footprint would be designated as 

open space. 

Within the 650 acre site, the facility area would include 

about 380 acres. The remainder would be left as 

vegetated and would serve as refuge habitat for more 

 

182 Based on preliminary footprint for the Memphis Regional IMF and 2009 imagery. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-87 

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mobile species (e.g., white-tailed deer (Odocoileus 

virginiana), raccoon (Procyon lotor), eastern cottontail 

(Sylvilagus floridanus), eastern gray squirrel (Sciurus 

carolinensis), beaver (Castor canadensis), muskrat 

(Ondatra zibethicus), bobcat (Lynx rufus)183 and various 

species of birds including waterfowl of Pond 4 and the 

riparian habitats surrounding Stream 6 would remain 

following project construction.

During construction activities, wildlife would be expected to 

vacate the site; some individuals of the less-mobile species 

(i.e., small mammals, reptiles, amphibians) could be lost 

during construction. Most wildlife would likely acclimate to 

human activity and return to adjacent areas following 

construction. From a 2004 aerial photograph, land within a 

one-mile perimeter around the site includes approximately 

10,500 acres.184 Approximately 3,200 acres appear to be 

forested and 7,300 acres appear to be non-forested.185 

This is very comparable to the percentage of land type 

within the planned facility footprint. 

Noise and light associated with the IMF may temporarily 

affect wildlife utilization of habitats. Because the main 

portion of the facility is located in a rural setting and is not 

located near a major airport, an interstate highway, or 

other major State and Local highways, noise and light are 

not already a factor within existing habitats. After 

development, areas that remain undisturbed within the 

property boundaries would, over time, provide some 

degree of refuge for local wildlife as the surrounding areas 

continue to urbanize. 

For light reduction, NSR would use fixtures that direct light 

downward to minimize the effects of the light to 

surrounding areas. To be able to operate the facility 

safely, the site would be graded to create a plateau for 

constructing a facility consisting of level tracks for rail cars 

to be placed for unloading and unloading of containers and 

trailers. To create the plateau, the majority of the eastern 

side of the facility would be in a cut that ranges up to 40-

foot deep in places. The western side of the facility would 

be constructed on a fill. Along the eastern and western 

boundary of the facility, where there is less than 10-foot in 

depth, NSR would construct a landscape berm where the 

top of the berm would be 10-foot higher than the top of 

pavement adjacent to the berm. Also along the western 

 

183 Wildlife North America, “List of North American Mammals,” http://www.wildlifenorthamerica.com/AZ/Mammal/common.html.

184 USDA, 2007 Aerial photograph. 

185 Visual estimates based on Imagery. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-88 

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edge of the proposed lead adjacent to the residences 

along Neville Road, NSR would construct a landscape 

berm where the top of the berm would be approximately 

15-foot higher than the adjacent top of rail. In the longterm, noise and light associated with the IMF would 

become part of the existing environment and would not 

likely impact wildlife in adjacent habitats appreciably. Over 

time, most wildlife species in adjacent habitats would adapt 

to the noise and light associated with the IMF. 

The No-Build Alternative would not be expected to have 

any immediate impact on flora and fauna with the project 

boundaries. 

3.12.2 Water Quality and Aquatic Resources 

The proposed Memphis Regional IMF would be situated 

within rolling topography at generally high elevations within 

the Wolf River watershed. The IMF would be at 

approximate elevation 385 feet amsl, with a maximum 

ground elevation of about 450 feet amsl due east of the 

site. The site is dissected by several streams and WWC, 

most of which originate within the IMF footprint. As such, 

the IMF would be at the headwaters of these features. 

Within the Wolf River watershed, the site is dissected by 

numerous WWC and small intermittent streams, which 

eventually flow into one of two unnamed tributaries of the 

Wolf River. As shown previously on Figure 3-19, several 

streams flow within close proximity to the proposed IMF 

footprint, lead tracks, proposed SR-57 overpass and 

Industrial Road. In general, these streams have sandy 

bottoms, eroding banks, and are typical for streams in this 

region. Two of these streams (Streams 4 and 5) originate 

on-site and are considered first order streams. These 

streams are intermittent and are relatively small, generally 

having a bottom width of approximately three to five feet. 

Streams 6, 7, and 11 are somewhat larger (bottom width of 

approximately 10 to 25 feet) and maintain a more constant 

flow. One additional small first order stream (Stream 3)

bisects the proposed lead tracks ROW. 

Several farm ponds were identified on or immediately 

adjacent to subject property. These impoundments range 

in size from less than one acre to 18 acres, Figure 3-19. 

Tennessee water quality standards require the 

incorporation of the Antidegradation Policy into regulatory 

decisions.186 In exceptional waters, degradation cannot 

 

186 Rules of Tennessee Department of Environment And Conservation, Water Quality Control Board, Division of Water 

Pollution Control, Chapter 1200-4-3, Aquatic Resource Alteration.
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-89 

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be authorized unless (1) there is no reasonable alternative 

to the proposed activity that would render it non-degrading, 

and (2) the activity is in the economic or social interest of 

the public. In Outstanding National Resource Waters, no 

new discharges, expansions of existing discharges, or 

mixing zones would be permitted unless such activity 

would not result in measurable degradation of the water 

quality. 

Due to the presence of Escherichia coli (E-coli), 

Tennessee classifies the unnamed tributaries of the Wolf 

River (TN08010210004-0400) that drain the site as 

impaired and lists them on the 2008 303d List. These 

streams are considered Category 4A, impaired. The EPA 

approved a pathogen total maximum daily load (TMDL) 

that addresses the known pollutants.187 The proposed 

Memphis Regional IMF could reduce the E-coli being 

deposited into these streams by not allowing livestock to 

graze within the IMF. 

The impacts reported in Table 3-16 are based on 

preliminary designs of the proposed Build Alternative 1. 

These preliminary designs have included minimization and 

avoidance of existing waters and sensitive areas. 

Impacts to Waters of the United States require 

authorization from the USACE under Section 404 of the 

CWA. Similarly, impacts to State waters require permits 

from the TDEC under the Aquatic Resource Alteration 

Permit (ARAP) program188 and Tennessee Water Quality 

Control Act189 and NPDES stormwater discharge program 

In conjunction with refinements in site design and Section 

404 and ARAP permitting, the impacts may increase or 

decrease once final design of Build Alternative 1 is 

completed. TMDL criteria will be appropriately addressed 

by TDEC via the project NPDES construction permit.190 

The proposed project would be designed to avoid and 

minimize impacts to aquatic resources to the extent 

practicable. Efforts to further minimize impacts would 

continue throughout the design, permitting, and 

construction process. 

 

187 TDEC, “Final Total Maximum Daily Load (TMDL) for E. Coli in the Wolf River Watershed (HUC 08010210) Fayette,

Hardeman, and Shelby Counties, Tennessee,” August 2007. 

188 Rules Of Tennessee Department Of Environment And Conservation, Water Quality Control Board, Division Of Water 

Pollution Control, Chapter 1200-4-7, Aquatic Resource Alteration. 

189 Tennessee Water Quality Control Act of 1977, TCA 64-3-101. 

190 http://www.epa.gov/owow/tmdl/intro.html#tmdlfitcwa. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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Table 3-16: Impacts to Aquatic Resources 

Aquatic Resource Potential Impacts 

(feet) Type of Potential Impacts Description 

STR-1 NA Runoff Intermittent Stream 

STR-2 50 Encapsulation Intermittent Stream 

STR-3 292 Encapsulation Intermittent Stream 

STR-4 700 Fill Intermittent Stream 

STR-5 3200 / 100 Fill/Encapsulation Intermittent Stream 

STR-6 250 Encapsulation Perennial Stream 

STR-7 200 Encapsulation Perennial Stream 

STR-10 NA Runoff Intermittent Stream 

STR-11 NA Runoff Perennial Stream 

PND-1 260 Fill Pond 

PND-2 NA Fill Pond 

PND-3 200 Fill Pond 

PND-4 300 Crossing/Encapsulation Pond 

PND-5 NA Fill Pond 

PND-6 NA Fill Pond 

Total Stream Impacts 5352 

Notes: 

1. Ponds 2, 5, and 6 (totaling 5.6 acres) are non-regulated, isolated farm ponds. 

2. Estimates are based on preliminary sketches; specific impacts would be calculated once a grading plan 

is finalized and permitting occurs. 

3. Impacts to wetlands are included in Table 3-17. 

4. Perennial streams based on USGS topographic map.191

5. Impacts to Stream 7 are related to the Industrial Road. 

6. Impacts to Stream 2 and a portion of the impacts to Stream 5 (approximately 50 feet) are related to the 

construction of the SR-57 overpass. 

7. Floodplain and aquifer impacts are discussed in Section 3.12.5 Floodplain Impacts and Section 3.12.6 

Aquifer Impacts. 

To minimize sedimentation and runoff impacts, erosion and 

sediment control plans would be included in the project 

construction plans. TDOT Standard Specifications for 

Road and Bridge Construction192, which include erosion 

and sediment control standards for use during 

construction, would be implemented in conjunction with the 

SWPPP and implemented in accordance with the NPDES 

 

191 USGS Topographic Quadrangle Map for Rossville, Tennessee (1981). 

192 TDOT, “Standard Specifications for Road and Bridge Construction,” 1 Mar 2006, 

http://www.tdot.state.tn.us/construction/specs.htm. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

construction permit under Section 402 of the CWA and 

Section 69 3 108 of the Tennessee Water Quality Control 

Act. 

The project is being designed to avoid and minimize 

wetland and stream impacts where practicable. Impacts to 

on-site aquatic resources have been minimized to achieve 

the basic project purpose. Design features that allow for 

avoidance and/or minimization of wetland and stream 

impacts include the following: 

 After determining minimum sizing of facility 

structures, site features were overlaid on 

topographic and wetland mapping to avoid 

impacting streams and wetlands, where possible. 

 Avoid re-channelization during bridge construction. 

 Design stream crossings at or near 90 degree 

angles, where practicable, to minimize stream 

impacts. 

 Design stream crossings to avoid meanders to 

reduce stream length impacts. 

 Maintain natural bottom of streams at crossings, 

where practicable. 

 Utilize rock drains to allow natural groundwater 

flows to continue to feed undisturbed downgradient 

segments of streams. 

 Use retaining walls to avoid placing fill in stream 

channels and/or stream relocations. 

 Minimize rechannelization when using culverts. 

The project was located to avoid streams and wetlands to 

the extent possible. Within the limits of geotechnical 

concerns, slopes were steepened to reduce the footprint of 

the facility on floodplains. Native material from other areas 

of the site and/or clean fill would be used as fill material in 

wetland areas. 

Although NSR is designing the facility to avoid major 

impacts to Stream 6 (Photo 3-6), the loop track and 

Industrial Road must cross it near the south end of the site. 

Two bridges are proposed to cross Stream 6. Both bridges 

would span the stream. No fill would be placed in the 

stream channel in association with these bridges. The 

preliminary design of the facility included a combined road 

Memphis Regional Intermodal Facility 3-91 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

and rail crossing of Stream 6, which would have required 

the relocation/channelization of Stream 6 due to the 

presence of meanders. By crossing Stream 6 in two 

locations, NSR would avoid channelization which would 

impact less length of stream because one of the crossings 

can be at a lower elevation. Impacts would be reduced 

from over 300 feet to less than 150 feet. 

Retaining walls are being designed near the loop track 

crossing and along the west side of the fill slope to further 

minimize impacts to Stream 6 and its associated 

floodplain. NSR would use retaining walls at two locations 

to avoid approximately 350 feet of in-stream impact to 

Stream 6 as well as impacts to the floodplain. 

For intermittent streams that lie within the footprint of the 

facility (such as Streams 4 and 5), avoidance and/or 

relocation are not practicable alternatives. Stream 4 is a 

small intermittent stream that originates on-site. Instead of 

filling the channel with earthen fill and eliminating the 

future seepage of groundwater to this surface feature, NSR 

would place rock fill within the existing stream channel 

(encapsulated beneath the facility) to help convey potential 

flows downstream to undisturbed portions of the stream. 

This would minimize impacts to functioning downstream 

portions of the stream. The length of Stream 4 filled with 

rock will be mitigated in accordance with the CWA. 

Stream 5 (Photo 3-7) is another small intermittent stream, 

which originates on-site. As the headwaters of Stream 5 

lie within the footprint of the facility, avoidance and/or 

relocation is not a practicable alternative. The beginning of 

Stream 5 lies in an area that would be undercut during 

project construction. To minimize impacts to downstream 

portions of the stream, NSR is designing for the collection 

of the existing Wet Weather Conveyances (WWC) so they 

would continue to feed Stream 5. The design includes a 

minimum amount of stormwater from the proposed track 

areas to be routed to a ditch that would flow into Stream 5. 

Runoff from the pads and the majority of the facility would 

be routed to an on-site stormwater detention system. The 

length of Stream 5 eliminated will be mitigated in 

accordance with the CWA. 

The largest wetland within the project site (Wetland 4) 

encompasses 2.84 acres. The loop track was originally 

designed to cross a portion of Wetland 4 and a meander of 

Stream 6. To avoid impacting Wetland 4 (Photo 3-8) and 

reduce impacts to Stream 6, NSR purchased additional 

property allowing the loop track to be shifted east. This 

Memphis Regional Intermodal Facility 3-92 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-93 

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would allow Build Alternative 1 to avoid impacting 300 feet 

of Stream 6 as well as 2.84 acres of Wetland 4. 

Appropriate Best Management Practices (BMP) would be 

followed to minimize erosion, turbidity, or other temporary 

impacts. Following minimization and avoidance measures, 

the project will impact both wetlands and streams. All 

impacts will be mitigated as required by regulatory 

agencies. Mitigation will be designed to meet the 

requirements of USACE and EPA’s Final Rule on 

Compensatory Mitigation for Losses of Aquatic 

Resources.193

Stream channels requiring relocation (channelization) 

would be replaced on site to the extent possible, using 

techniques that would replace existing stream 

characteristics such as length, width, gradient, and tree 

canopy. Water body impacts that cannot be mitigated onsite, such as impacts to springs that require rock fill, would 

either be mitigated off-site by improving a degraded 

system or by making a comparable payment to an in-lieufee program. An in-lieu-fee program would perform off-site 

mitigation under the direction of State and Federal 

regulatory and resource agencies. 

The State of Tennessee sets water quality standards, 

including water quality criteria, for waters of the State. The 

water quality standards are established at levels protective 

of designated uses and to protect aquatic life and water 

quality in accordance with the Clean Water Act (CWA). 

Water Quality Standards must be met during construction 

and operation of the proposed project, and are a 

requirement of permits issued by TDEC for discharges to 

waters of the State. Therefore, the project would not 

cause or contribute to a violation of water quality standards 

and accordingly is not expected to adversely affect water 

quality in the area. In addition, NSR will coordinate with 

TDEC Division of Ground Water Protection in order to 

protect the quality of groundwater in the area. 

Build Alternative 1 would impact several streams (totaling 

approximately 5,352 linear feet of impact, Table 3-16) 

within the footprint of the facility and the SR-57 overpass. 

Much of this stream length is currently listed as “impaired”. 

The unavoidable loss of stream channel will be offset 

through compensatory mitigation. Potential water quality 

impacts would be minimized through the implementation of 

 

193 (Apr. 10, 2008) issued pursuant to Section 404 of the CWA, 33 U.S.C. § 1344, and regulations at 33 C.F.R. Part 332 

and 40 C.F.R. Part 230. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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BMP and other regulatory requirements so that water 

quality in the area will not be significantly impacted. 

The No-Build Alternative would not be expected to impact 

stream resources or water quality in the area with the 

following exceptions: 

 Industrial Road would cross Stream 7 and is 

being built under Tennessee NPDES Permit, 

TNR152966, and TDEC ARAP Permit, 

NR0905.065. 

 Several streams within the project site are listed 

as impaired by TDEC for Escherichia coli (E. 

Coli). The IMF could potentially improve this 

condition by reducing livestock grazing (a 

potential E. Coli source) at the site. 

3.12.3 Wetland Resources 

Wetlands are defined by the USACE and the EPA as 

“those areas that are inundated or saturated by surface or 

groundwater at a frequency or duration to support, and that 

under normal circumstances do support, a prevalence of 

vegetation typically adapted for life in saturated soil 

conditions. Wetlands typically include swamps, marshes, 

bogs and similar areas.”194

Approximately 7.5 acres of confirmed wetlands at 11 sites 

have been identified within or near the anticipated project 

limits (Figure 3-19 and Table 3-17). Jurisdictional 

determination of these wetlands was confirmed by the 

USACE. 

Efforts to further minimize impacts will continue throughout 

the design, permitting, and construction process. Impacts 

from construction of the proposed Memphis Regional IMF 

and the proposed SR-57 overpass will be permitted 

simultaneously. Industrial Road is under construction in 

Tennessee (Tennessee NPDES Permit Tracking Number 

TNR152966195) and is not expected to impact any 

wetlands. 

Mitigation is required for all wetland impacts that do not 

meet the requirements for the State of Tennessee’s 

general ARAPs or for certain Nationwide Section 404 

permits (USACE). Following minimization and avoidance 

measures in accordance with Chapter 1200-4-7, some 

 

194 33 CFR 328.3. 

195 Permit issued to Mr. William Adair by TDEC Memphis EFO on November 2008 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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wetlands and streams within the footprint of the facility will 

be impacted by the project. All wetland and stream 

impacts will be mitigated.196

Table 3-17: Impacts to Wetlands 

Wetland 

Type 

Type of 

Potential 

Impacts 

Primary Function 

of Wetland 

Potential Impacts 

(acres) 

Description 

Total 

Likely 

Elimination 

or Drained 

WTL-1 

Emergent Fill Wildlife Habitat and 

Watering 0.01 0.01 Small, low quality, depressional 

area in field 

WTL-2 

Emergent Fill Wildlife Habitat and Watering 0.16 0.16 Small, low quality, depressional area in field 

WTL-3 

Fringe Fill Wildlife Habitat and Watering 0.04 0.04 Fringe wetland 

WTL-4 

Emergent Fill Wildlife Habitat and 

Watering 2.84 2.84 Herbaceous wetland with scattered 

trees located on broad flat area. 

WTL-5 

Fringe Fill Wildlife Habitat and 

Watering 0.21 0.21 Fringe wetland 

WTL-6 

Fringe Fill Wildlife Habitat and Watering 0.01 0.01 Fringe wetland 

WTL-7 

Fringe Fill Wildlife Habitat and 

Watering 0.77 0.77 Fringe wetland 

WTL-8 

Fringe Fill Wildlife Habitat and 

Watering 0.57 0.57 Fringe wetland 

WTL-9 

Emergent No impact Wildlife Habitat and Watering 0.20 0.00 Small, low quality, depressional area in field. 

WTL-10 

Emergent Fill Wildlife Habitat and 

Watering 2.70 2.70 Herbaceous wetland with scattered 

trees located on broad flat area. 

WTL-11 

Emergent No impact Wildlife Habitat and 

Watering 0.02 0.00 Small, low quality, depressional 

area in field 

Total Wetland Impacts 7.53 7.31 

* Estimates are based on preliminary sketches; specific impacts will be calculated once grading 

plan is finalized and permitting occurs.

The minimum replacement ratio for wetlands is 2:1 and 

may be higher depending on hydrogeomorphic analyses or 

if optimum mitigation sites are unavailable. Wetland 

impacts may be mitigated through on-site or off-site 

mitigation. In addition, the credits in a wetland mitigation 

bank may be purchased to off-set impacts. 

 

196 Mitigation will also be designed to meet the requirements of USACE and EPA’s Final Rule on Compensatory 

Mitigation for Losses of Aquatic Resources (Apr. 10, 2008) issued pursuant to Section 404 of the CCWA, 33 U.S.C. § 

1344, and regulations at 33 C.F.R. Part 332 and 40 C.F.R. Part 230. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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It is anticipated that approximately 7.3 acres would be filled 

as a result of the construction. Efforts will be made; 

however, during further project design, to avoid or 

minimize impacts to as many of these sites as possible. 

Any project related impacts to wetlands within the project 

limits will be mitigated as required by the appropriate 

permitting agencies. It is anticipated that mitigation will be 

accomplished by purchasing wetland mitigation credits 

from the Wolf River Mitigation Bank, LLC197, which is 

within the same 8-digit HUC watershed as the project. 

There would be no wetland impacts for the No-Build 

Alternative. 

3.12.4 Channelization of Streams 

The proposed Memphis Regional IMF will be constructed 

in accordance with all applicable rules and regulations 

regarding channelization as required in TDOT’s Standard 

Specifications for Road and Bridge Construction. 

Construction of the proposed Memphis Regional IMF 

would include bridges and culverts to cross existing and 

proposed drainage features. For bridge construction, no 

channelization would occur as a result of the project. 

Minimal channelization would occur with the culverts. If 

stream channels requiring relocation cannot be replaced or 

otherwise mitigated on-site, additional mitigation measures 

(i.e., in-lieu-fee programs) would be utilized in accordance 

with applicable laws and regulations. 

The No-Build Alternative would not necessitate any 

channelization of streams. 

3.12.5 Floodplain Impacts 

In accordance with EO 11988: Floodplain Management, an 

assessment of impacts to the floodplains was conducted. 

Floodplains are low-lying areas located adjacent to the 

channel of a river, stream or other type of waterbody.198

These areas are subject to periodic flooding during heavy 

rains and/or long periods of wet weather. Floodplains are 

important because they: 

 Provide temporary storage of flood waters; 

 Prevent severe erosion caused by quickly flowing 

water; 

 

197 http://www.mvm.usace.army.mil/regulatory/MBL/mitigation_bank_listing.htm. 

198 FEMA. Flood Insurance Rate Map, Fayette County, Tennessee, Map # 47047C0415C. Effective Date: November 5, 

2008 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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 Provide a vegetative buffer that filters silt and 

contaminants from runoff before it enters a stream 

or other waterbody; and 

 Recharge and protect groundwater. 

Areas of Fayette County are subject to periodic inundation 

from flooding and are regulated by the Fayette County 

Flood Damage Reduction District. Fayette County’s 

floodplain management regulations are set to ensure that 

proposed development within any flood prone areas (within 

the 100 yr flood) does not create significant adverse affects 

to public safety or create substantial environmental 

impacts. These regulations are organized to ultimately 

ensure that development is in compliance with the 

regulations from the National Flood Insurance Program 

(NFIP). Some of the County’s sub-sections exceed the 

parameters of the NFIP in order to address items of 

specific concern to the county’s future growth while 

protecting the public from risks. 

Because the Memphis Regional IMF is partially located 

with a flood prone area, the design would take into account 

the Fayette County Regulations. Under the Standards for 

Streams for areas of Special Flood Hazard, Zone AE and 

Zone A (where streams exist, but no base flood data has 

been provided), Fayette County applies the following 

provisions: 

 New construction shall comply with all applicable 

flood hazard reduction provisions. 

 No encroachments shall be located within an area 

equal to the width of the stream or twenty feet, 

whichever is greater unless a professional engineer 

demonstrates the cumulative effect of the proposed 

development will not increase the water surface 

elevation or the base flood more than one foot at 

any point within the community.199 

As part of the Memphis Regional IMF, none of the 

buildings are within the floodplain. For encroachment in 

Zones AE or A, a professional engineer would certify that 

these encroachments would not increase the water surface 

elevation of the base flood more than one foot at any point 

within the community. 

Based on Flood Insurance Rate Map (FIRM), the southern 

portion of the project area encompasses an unnamed 

 

199 Fayette County “Flood Damage Reduction District” Resolution. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-98 

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tributary of the Wolf River (identified as Stream 6).200 A 

special flood hazard area (SFHA), or 100-year 

floodplain, has been delineated for this portion of the 

unnamed tributary of Wolf River. The SFHA is identified as 

Zone A, indicating the 100-year floodplain was determined 

by approximate methods depicted in Figure 3-20 No base 

flood elevations or depths of flooding are shown within this 

zone. 

Figure 3-20: Flood Hazard Area 

Additionally, the northeast corner of the project review area 

encompasses approximately four acres of the 

 

200 FEMA, 2008. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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SFHA delineated for the Wolf River. This SFHA is 

identified as a Zone AE indicating the 100-year floodplain 

was determined by detailed methods.201 Base flood 

elevations were determined by detailed hydraulic analysis. 

The facility would be sited outside of the Wolf River 

floodplain (Zone AE) except for potential impacts when the 

lead tracks tie back into the NSR mainline. The project 

encompasses multiple streams. Only Stream 6 has a 

designated floodplain within the facility. The Industrial 

Road and loop track would cross Stream 6 within its Zone 

A. These crossings cannot be avoided, but the design will 

cause a “no-rise” condition with respect to floodwaters or 

will limit any such impacts to on-site areas. Design 

adjustments include methods to prevent fill encroachment 

into the Zone A floodplain along Stream 6, including walls 

or gabion structures along the toe of fills and lowering the 

height of stream crossings to reduce the length of impacts. 

The floodplain/riparian habitat along Stream 6 is outside of 

the clearing limits and would be left undisturbed by 

construction and operation of the project, except for 

potential temporary impacts for bridge construction. 

As discussed in additional detail in Section 3.12.7, NSR 

has proposed to develop a stormwater control system that 

would provide storage to allow discharges to mimic predevelopment hydrology and minimize initial flows following 

rain events and also decrease resultant peak flows. The 

stormwater control system features several detention 

basins to capture and treat stormwater runoff from the 232 

acre paved concrete container and trailer transfer and 

parking area within the operating yard. To prevent 

excessive runoff from entering the receiving streams 

during and following rainfall events, NSR would design and 

implement a stormwater detention system that would 

operate during both construction and operation of the 

facility. The stormwater detention system would be 

designed so that post-construction flows do not exceed 

pre-construction flows (designed for the 100-year event). 

The Memphis Regional IMF area is less than 1.5% of the 

12-digit HUC Wolf River Subwatershed (43,204 acres) with 

the project draining into the Unnamed Tributary to Wolf 

River (TN08010210004–0400). The less pervious areas of 

the IMF, approximately 233 acres of paved surface and 76 

acres of track, is less than 2% of the portion of the 0301 

subwatershed south of the Wolf River between Piperton 

and Rossville (approximately 15,500 acres). 

 

201 FEMA, 2008. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-100 

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Executive Order 11988 requires federal agencies to avoid 

to the extent possible, the long and short-term adverse 

impacts associated with the occupancy and modification of 

flood plains and to avoid direct and indirect support of 

floodplain development wherever there is a practicable 

alternative. Analysis of floodplain impacts have been 

performed in conjunction with the project design, and 

avoidance of impacts to the floodplain is a major design 

feature. Additional details on potential floodplain impacts 

are provided in EA Sections 3.12, 3.18, and 3.19 and 

included in submittals to federal agencies with respect to 

NEPA and permitting for the project. In summary, the 

entire facility has been sited outside of the Wolf River 

floodplain, except for potential impacts when the lead 

tracks tie back into the NSR mainline, which has existed in 

its location for decades. This connection to the mainline 

and minimal encroachment on the floodplain is not 

avoidable and there is no practicable alternative to this 

connection. 

Facility impacts from post-construction hydrology and 

impacts to the Zone A floodplain will be avoided, 

minimized, or mitigated during project design. The facility 

would be designed to ensure that pre- and post-hydrology, 

including stormwater discharge from the site, will not 

change significantly due to the project. NSR has adopted 

the construction and maintenance practices outlined in the 

local floodplain practices, to the extent practicable, and do 

not anticipate floodplain impacts. 

In accordance with EO 11988, the analysis of floodplain 

impacts includes provisions of the Clean Water Act, the 

National Flood Insurance Act, the Flood Disaster 

Protection Act, and other applicable provisions relating to 

floodplain impacts. For this project, NSR would adopt all 

construction and maintenance practices in Fayette 

County’s floodplain management regulations and obtain 

the appropriate zoning authorizations from Fayette County 

for this project. While NSR plans to voluntarily comply with 

such local criteria whenever possible, there may be 

instances where those criteria are incompatible with rail 

operations.202 For this project, as noted above, 

substantive local floodplain measures to the extent 

 

202As noted in Section 3.1 of the EA, in recognition of the importance of rail transportation in interstate commerce, 

Congress has enacted legislation providing that federally regulated railroads operating in interstate commerce are not 

subject to otherwise applicable local and state laws. See Interstate Commerce Commission Termination Act of 1995 

("ICCTA"), 49 U.S.C. § 10501 and the Federal Railway Safety Act of 1970 ("FRSA"), 49 U.S.C. § 20101 et seq. In 

accordance with these and other similar federal laws, most state and local regulation of railroads is preempted in order to 

ensure barriers to interstate commerce are not created. This includes local planning, zoning and similar laws and 

ordinances. However, as discussed in this section, NSR will adopt local floodplain impact practices for this project. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

applicable to rail have been included in construction 

specifications. 

The water crossings would be designed to convey 

floodwaters so that there would be no major risk of 

property damage or loss of life due to the encroachment in 

the floodplains. Construction would ensure that an 

evacuation route is provided for local residents and 

businesses. Attempts will be made to minimize impacts to 

the unnamed tributary to Wolf River (Stream 6) floodplain 

in project design. If impacts to the floodplain occur, the 

design selected for the floodplain encroachment will be 

supported by analysis of design alternatives with 

consideration given to: capital costs and risks; and 

economic, social and environmental concerns. 

Based on the proposed design features discussed above 

and in Section 3.12.7, the Memphis Regional IMF should 

not have an adverse affect on the floodplain including 

riparian habitat and local residences/businesses. 

The No-Build Alternative will not involve any immediate 

impacts to floodplains. 

3.12.6 Aquifer Impacts 

The Memphis Sand aquifer is part of a sequence of water 

bearing aquifer units that forms the Mississippi Embayment 

(Figure 3-21) and underlies a vast area including parts of 

Kentucky, Tennessee, Alabama, Arkansas, Mississippi, 

Louisiana and Texas. 

Figure 3-21: Mississippi Embayment Area

The Memphis Sand of the Claiborne Group underlies 

approximately 7,400 square miles in western Tennessee, 

Memphis Regional Intermodal Facility 3-101 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-102 

6/30/2010 

including Fayette County as shown in Figure 3-22.203 The 

proposed Memphis Regional IMF is located within the 

potential recharge area of the Memphis Sand Aquifer. 

Figure 3-22: West Tennessee Memphis Sand - Major Physiographic Subdivision

The Memphis Sand ranges from 0 to about 900 feet in 

thickness. Where the original thickness is preserved, it is 

about 400 to 900 feet thick. The unit is U-shaped such 

that wells in the Memphis area are typically 400-500 feet 

deep, Figure 3-23. In fact, the sequence of strata 

approximately equivalent to the Memphis Sand was 

referred to as the “500-foot” sand in many early reports for 

the Memphis area. Recharge to the Memphis Sand 

aquifer is, in part, from precipitation on the outcrop which is 

located along the eastern edge of the formation in 

proximity to Build Alternative 1. In the outcrop-recharge 

belt, the Memphis Sand aquifer is considered to be under 

 

203 The University of Memphis Groundwater Institute, “History of Memphis Groundwater,” 

http://gwi.memphis.edu/webpages/history.html. 

Project Area 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-103 

6/30/2010 

water-table conditions (unconfined). In this area, the 

potentiometric surface is complex and generally conforms 

to the topography.204 

Figure 3-23: Memphis Sand Layers

West of this area, the aquifer is confined. In general, the 

groundwater flow direction in the Memphis area is to the 

west and northwest.205 The Town of Collierville is located 

northwest of the project area. Collierville draws its drinking 

water from the Memphis Sand aquifer. Aquifer recharge 

and transmissivity characteristics are such that 

groundwater in the Collierville wells is considered to be 

relatively “young”, on the order of 30-50 years old.206 

 

204 W.S. Parks and J.K. Carmichael, “Geology and Ground-Water Resources of the Memphis Sand in Western 

Tennessee,” Water-Resources investigation Report 88-4182, (U.S. Geological Survey,) 1990. 

205 Schrader, T.P. 2008, Potentiometric Surface in the Sparta-Memphis Aquifer of the Mississippi Embayment, Spring 

2007. 

206 Discussion between the Town of Collierville and the University of Memphis Groundwater Institute. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-104 

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As noted previously, Build Alternative 1 (total project area 

of 650 acres) is located within the potential recharge area 

of the Memphis Sand aquifer. The IMF footprint would 

encompass 380 acres consisting of approximately 233 

acres of paved surface and 76 acres of track. The 

recharge area covers over 2,200 square miles in west 

Tennessee alone, Figure 3-24.207 Consequently, the 

planned facility would impact a surface area of less than 

0.03% within the potential recharge area in West 

Tennessee alone. 

Figure 3-24: West Tennessee Memphis Sand Recharge Outcrop Area

Soil borings completed for the project encountered variable 

materials including clay, sandy-clay, silty-clay, silty-sand, 

and clayey-sand. The borings did not encounter distinct 

intervals of clean sand. The clayey-sand material is 

potentially part of the Memphis Sand. The borings indicate 

that layers of clay are present below the proposed 

Memphis Regional IMF site.208 These clay layers are 

probably discontinuous but greatly reduce the vertical 

permeability of the soil in this area. The discontinuous 

nature of the clay layers however, means that the clayeysands in the project area are interconnected with the 

confined aquifer northwest of the site. 

 

207 Water-Resources investigation Report 88-4182, “Geology and Ground-Water Resources of the Memphis Sand in 

Western Tennessee”, U.S. Geological Survey, 1990, by W.S. Parks and J.K. Carmichael. 

208 Insert Geotech report reference 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-105 

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A large percentage of aquifer recharge occurs along 

exposures within the bottoms of streams and rivers where 

a relative constant or consistent source of water is present 

to infiltrate the sandy material. These features will remain 

largely intact at the project area although some of the 

smaller streams will be eliminated, crossed or 

encapsulated. As such, recharge via such features should 

be preserved. As discussed in additional detail in this 

section, NSR has proposed to develop a stormwater 

control and management system that would mimic predevelopment site hydrology. In doing so, peak discharges 

to streams following rainfall events would not exceed predevelopment flows. Likewise, post-development flows in 

the streams should be similar to pre-development flows. 

The stormwater detention system would be designed so 

that post-construction flows do not exceed pre-construction 

flows (designed for the 100-year event). 

A number of residential water wells are present around the 

project site along Knox Road, Neville Road, and SR-57. 

As reported by TDEC Ground Water Management Section, 

these wells are relatively shallow on the order of 90-150 

feet deep.209 Based on topographic relief in the area and 

on the planned elevation of the facility, most of the 

screened well intervals should be 80 to 150 feet below the 

planned IMF elevation. The Town of Rossville obtains its 

water from three groundwater wells ranging from 90-102 

feet deep.210 Piperton obtains its water from Collierville. 

Collierville’s water supply is taken from eleven deep wells 

pumping from 350 foot and 600 foot sands.211 As 

discussed in additional detail in Section 3.12.6 and Section 

3.13, NSR has proposed construction techniques that 

would provide protection to the underground water sources 

during construction and operation of the facility. Federal 

hazardous materials transportation laws and regulations 

limit freight that can and cannot be shipped through 

intermodal service. As discussed in additional detail in 

Section 3.16, NSR has an extensive spill prevention 

program. 

Well heads are not expected within the limits of the project 

site. During construction, if such features are encountered, 

they will be properly plugged and abandoned by a 

Tennessee licensed well contractor in accordance with 

TDEC criteria. 

 

209 TDEC 2009, Ground Water Management Section, Database Information on Commercial and Residential Wells in 

Fayette County. 

210 Town of Rossville, Rossville Waterworks, 2007 Water Quality Report. 

211 Collierville Chamber of Commerce website: http://www.colliervillechamber.com/economic/utilities.htm#Water. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

During operation of the facility, all surface drainage from 

the production areas would be collected and routed 

through lined-detention basins to ensure water quality 

meets applicable standards prior to discharge. The basin 

system would include appropriate positive controls in the 

unlikely event of a spill at the site in order to contain fluids 

until appropriate cleanup actions are taken. In addition to 

being lined with compacted clayey soil to reduce 

infiltration, the basins would also be designed to reduce 

standing water. The maintenance pad for site equipment 

would likewise include a controlled drainage and treatment 

system so that drainage from the site will comply with State 

and Federal water quality standards. 

Construction and site grading work would follow standard 

NSR specifications with project specific requirements to 

provide additional protection for potential exposures of the 

Memphis Sand. In particular, NSR’s standard 

specifications require that the subgrade within all areas of 

cut, scarified, and re-compacted to provide a uniform 

bearing surface. Due to the clayey nature of the site soils, 

this would provide a relatively low permeability surface of 

the prepared subgrade. In addition, NSR will require that 

the bottoms of the detention basins and any Memphis 

Sands within the facility footprint exposed at the planned 

subgrade level, be lined or covered with at least a 12-inch 

thick layer of clayey material, preferably a low plasticity 

clay (CL) or high plasticity clay (CH) material, and that the 

cover layer be compacted to 100% Standard Proctor per 

AASHTO T99. The liner or cover material will be placed at 

a moisture content of between -1% to +4% optimum 

moisture. 

NSR’s standard construction specifications for placement 

of fill material include the following: 

 Earth fill must be placed in uniform layers of not 

more than 6 inches thick after compaction. 

 In a fill section, after stripping topsoil and organic 

material, the entire area where the embankment is 

to be placed shall be plowed and scarified for a 

minimum depth of 6 inches. This surface and all 

future fill layers shall be compacted to 95 percent of 

maximum density per Standard Proctor in 

accordance with AASHTO T 99 or 90 percent of 

maximum density per Modified Proctor in 

accordance with AASHTO T180, except that a 

minimum of the top 2 feet of fill shall be compacted 

to 100 percent Standard Proctor. 

Memphis Regional Intermodal Facility 3-106 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

 The top 12 inches of the subgrade in cuts shall be 

plowed, scarified and compacted to 100 percent 

Standard Proctor. The Engineer shall determine 

the AASHTO test method to be used after review of 

the soil analysis. 

 Moisture content of soil shall be controlled as 

necessary to obtain the specified densities based 

upon the optimum moisture content for each 

material. 

Once the site is graded to the required elevation, the 

temporary and/or permanent ditches, culverts, and/or 

under-drains would be installed to provide positive 

drainage across the site. During construction of the paved 

concrete container and trailer transfer and parking areas 

within the operating yard, positive drainage to interior catch 

basins would be established to reduce the potential for 

standing or ponding water. The interior catch basins would 

be installed to collect storm water from the proposed 

pavement surfaces. Above the soil subgrade, a 6 inch 

layer of aggregate would be placed in the operational yard, 

maintenance area/pad, and entrance area. For planned 

operations, the best operational paved surface for the 

facility is roller compacted concrete. The concrete would 

be placed on top of the aggregate layer. It would range in 

thickness from 9 to 17 inches based on the type of 

equipment, which would be operating in specific areas of 

the IMF. 

Concrete is a commonly used environmental measure to 

prevent or reduce the amount of pollutants that could 

otherwise infiltrate directly into sub-grade and potentially 

into the aquifer. Concrete protects the aquifer in two major 

ways. First it prevents materials from contacting site soils, 

effectively containing any materials from operational areas. 

Second, concrete prevents rain from contacting soil and 

allowing for movement of materials into the groundwater. 

Accordingly, the concrete within operating portion of the 

yard would cover the exposed sub-grade, which could 

include outcrops of the potential Memphis Sand recharge 

zone. In addition, under the concrete is at least a 12-inch 

thick layer of compacted subgrade material. Should areas 

of the Memphis Sand be exposed during excavation, the 

12-inch thick layer of compacted subgrade material would 

be clayey soil. 

Maintenance and fueling activities from IMF equipment 

would occur within the maintenance pad area. Included in 

this area would be five (5) ASTs ranging in size from 300 

to 3,000 gallons. The larger AST would be for storage of 

Memphis Regional Intermodal Facility 3-107 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-108 

6/30/2010 

diesel fuel. Per EPA regulations, the ASTs are required to 

have secondary containment.212 The stormwater from the 

maintenance pad would be treated via an oil-water 

separator. The pollutants would be disposed of through 

the Rossville separate sewer system. The remaining 

stormwater would be discharged into a Bio-Treatment 

Pond. The bio-treatment pond is not lined to allow for 

vegetation and natural processes to function as designed. 

Effluent from the bio-treatment pond would pass through 

a lined storm water detention basin. The only fueling, 

which would not occur on the maintenance pad, is limited 

to locomotives. The IMF does not include locomotive 

maintenance or permanent fueling facilities. 

The IMF operation would employ appropriate BMP to 

protect the recharge area and the quality of the stormwater 

that may eventually enter the groundwater regime. 

Stormwater from above the cut slope would be directed in 

a ditch along the lead track into Stream 5 or Stream 6, 

based on the sites current drainage pattern. The 

construction of the paved concrete container and trailer 

transfer and parking area within the operating yard and 

maintenance pad area would eliminate direct recharge in 

this 233 acre section of the IMF. Of the 650 acre project 

area, 270 acres outside of the 380 acre facility would be 

either left natural or restored to open or green space, 

which would allow for continued recharge. The majority of 

the stormwater collected on the paved operating yard 

would discharge into Stream 6 after passing thru the 

stormwater basins, which fundamentally matches the preconstruction drainage pattern. The stormwater directed to 

Streams 5 and 6 would allow recharge to occur through the 

Unnamed Tributary of Wolf River. According to the 

University of Memphis, Groundwater Institute, 95% of the 

recharge of the aquifer occurs through the area’s 

streams.213 

Stormwater that falls on the pad area would be collected in 

a series of catch basins and culverts. The culverts would 

daylight into ditches and into multiple permanent 

stormwater basins. The basins would be constructed with 

a low permeability layer to minimize infiltration. 

NSR has a very successful spill prevention program. Only 

four spills were recorded in the last two years (2008-2009) 

at NSR owned and operated 27 intermodal facilities among 

4.96 million intermodal containers and trailers moved. The 

site-specific spill prevention plans for the Memphis 

 

212 40 C.F.R 112.7. 

213 Meeting between AMEC, TDEC EFO, and GWI on March 16. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Regional IMF would outline the standard processes and 

procedures to be implemented in the unlikely event of a 

spill or release. The plan would include appropriate 

personnel training and be updated as needed. Spill kits 

would be on-site in the maintenance pad area and with the 

fueling trucks. For example, an NSR standard operating 

procedure for fueling a locomotive on the track, states that 

the contractor must use a portable containment tank to 

catch any spills. If spills occur (no matter the size), they 

are immediately reported and the designated spill clean-up 

contractor is contacted to perform the clean-up. The 

contractor would remove and properly dispose of the 

contaminated material. 

Because the very few hazardous materials utilized at the 

IMF or transported, and the very low likelihood of a 

release, as described in Section 3.16, the measures above 

would be considered precautionary in nature as 

environmental enhancement measures toward the 

protection of groundwater and aquatic resources. Based 

on the measures taken as part of the construction and 

operation of the Memphis Regional IMF, no adverse 

impacts are expected from Build Alternative 1 on the 

quantity or quality of groundwater in the area. 

The No-Build Alternative has no effect on the Memphis 

Sand Aquifer. 

3.12.7 Stormwater Impacts 

NSR would to develop a stormwater treatment system that 

would provide storage to allow discharges to mimic predevelopment hydrology and minimize initial flows following 

rain events and also decrease resultant peak flows. The 

stormwater treatment system features a several detention 

basins approach to capture and treat stormwater runoff 

from the 232 acre paved concrete container and trailer 

transfer and parking area within the operating yard. To 

prevent excessive runoff from entering the receiving 

streams during and following rainfall events, NSR would 

design and implement a stormwater detention system that 

would operate during both construction and operation of 

the facility. The stormwater detention system would be 

designed so that post-construction flows do not exceed 

pre-construction flows (designed for the 100-year event). 

This stormwater management system provides substantial 

water quality benefits, but is not required under CWA 

National Pollutant Discharge Elimination System (NPDES) 

provisions because the stormwater discharged from the 

proposed Memphis Regional IMF does not fall within the 

Memphis Regional Intermodal Facility 3-109 

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3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-110 

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category of industrial stormwater from transportation. For 

transportation facilities like the Memphis Regional IMF, 

EPA only regulates post-construction stormwater 

discharges from vehicle maintenance and equipment 

cleaning operations, and specifies that only those portions 

of a rail transportation facility that are involved in such 

operations constitutes regulated stormwater from industrial 

facilities.214 The stormwater management system 

receives runoff from the pads and track areas, which do 

not constitute industrial stormwater. The detention 

facilities will provide stormwater treatment above and 

beyond the requirements of the Tennessee Multi-Sector 

General Permit for the Discharge of Storm Water from an 

Industrial Activity (TMSP) No. TNR050000 and the 

discharge will meet water quality standards established by 

the State of Tennessee for the receiving water bodies. 

NSR will develop a Storm Water Pollution Prevention Plan 

(SWPPP) applicable to the entire facility, not just those 

vehicle maintenance and equipment cleaning operations 

addressed by the NPDES program. 

The stormwater management system also serves a dual 

function. The drainage system for the facility would include 

valves at the outlets to the stormwater management 

system to allow the detention basin outfalls to be closed 

under certain circumstances. NSR would include these 

valve closures to allow the on-site detention to serve a 

secondary function for spill control in the unlikely event that 

a release of materials occurs that exceeds the containment 

capacity of the on-site concrete pad. NSR has installed 

similar detention valves at other facilities and their use has 

been rare. 

NSR also evaluated multiple potential locations, sizes, and 

configurations of detention basins in order to reduce 

impacts of stormwater from both a hydrological and water 

quality perspective. In terms of locations, detention basins 

location will avoid use of streams, wetlands, or other 

waters of the State or U.S.215 Locations have been 

assessed to minimize impact to on-site habitat. 

Additionally, NSR also considered locations for necessary 

stormwater management facilities required during 

construction.216 The basins would be lined with at least a 

12-inch thick layer of compacted clayey soil to reduce 

infiltration. NSR would use appropriate BMP for 

 

214 TDEC, Tennessee Storm Water Multi-Sector General Permit for Industrial Activities No., TNR050000 (NPDES), 40 

C.F.R. § 122.26(b)(14)(viii). 

215 TDEC Division of Water Pollution Control, “Aquatic Resource Alteration Permit (ARAP),” Chapter 1200-4-7 Aquatic 

Resource Alteration. 

216 TDEC General NPDES Permit for Discharge of Stormwater Associated with Construction Activities, Permit No. 

TNR100000. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-111 

6/30/2010 

construction stormwater management in accordance with 

TDEC and EPA guidelines to protect local waterbodies. 

For personal vehicle parking areas, NSR would use 

approximately 1 acre of pervious concrete. Per Leadership 

in Energy and Environmental Design (LEED) guidance, 

pervious pavement is a common usage for employee 

parking lots.217 This would reduce the amount of 

stormwater flows from the site. 

To avoid creating unstable slopes, NSR would use 3:1 

slopes in most areas of the facility. The use of 3:1 slopes 

instead of 2:1 slopes would reduce the potential for erosion 

and potential sedimentation into streams during storm 

events. 

The general hydrology of the site is the Wolf River 

Watershed (08010210) as classified by USGS. It drains 

819 square miles across Tennessee and Mississippi 

(Figure 3-25).218 The Wolf River empties into the 

Mississippi River Watershed (08010100). The Wolf River 

Watershed is characterized by a large river system with 

wide floodplains. The streams are low-gradient and murky 

with silt and sand bottoms. 

 

217 U.S. Green Building Council, “Improvement of Porous Pavement System for on‐site Stormwater Management, 2008 

http://www.usgbc.org/ShowFile.aspx?DocumentID=5306. 

218 TDEC, Wolf River Watershed (08010210) of the Mississippi River Basin, Watershed Management Plan, December 

17, 2005. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-112 

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Figure 3-25: Location of Wolf River Watershed 

The Wolf River Watershed is divided into three 10-digit 

HUC subwatersheds. The Memphis Regional IMF, SR-57 

overpass and part of Industrial Road would be sited in the 

10-digit HUC Wolf River Subwatershed (0801021003), the 

largest of the three. This subwatershed covers 227,618 

acres.219 A further division of the watershed places the 

site into the 12-digit HUC subwatershed of 0301 

(080102100301).220 The 0301 subwatershed has 

contributing drainage area on both sides of the Wolf River 

as shown in Figure 3-26. The project area is less than 

1.5% of the 12-digit HUC subwatershed (43,204 acres). 

The project area would drain into the Unnamed Tributary to 

Wolf River (TN08010210004–0400). The less pervious 

areas of the IMF, approximately 233 acres of paved 

surface and 76 acres of track, is 2% of the portion of the 

0301 subwatershed south of the Wolf River between 

Piperton and Rossville (approximately 15,500 acres). 

 

219 TDEC, Wolf River Watershed, Watershed Management Plan, December 17, 2005. 

220 In 2009, TDEC renumbered subwatersheds within the Wolf River. The numbers within the report are the unchanged 

numbers. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-113 

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Figure 3-26: Wolf River Subwatershed 0301 

The general hydrology of Industrial road is a mixture 

between the Wolf River Watershed (08010210) and the 

Nonconnah Creek Watershed. The Nonconnah Creek 

Watershed (08010211) drains 281 square miles across 

Tennessee and Mississippi (Figure 3-27).221 The 

Nonconnah Creek empties into the Mississippi River 

Watershed (08010100). The Nonconnah Creek 

Watershed is characterized by gently rolling, irregular 

plains. The streams are low-gradient and murky with silt 

and sand bottoms. 

 

221 TDEC, Nonconnah Creek Watershed (08010211) of the Mississippi River Basin, Water Quality Management Plan, 

November 9, 2000. 

Subwatershed 0301 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Figure 3-27: Nonconnah Creek Watershed 

The No-Build Alternative has no effect on existing 

stormwater. 

3.12.8 Threatened and Endangered Species 

Pursuant to Section 7 of the Endangered Species Act 

(ESA), coordination and consultation has been conducted 

with the U.S. Fish and Wildlife Service (FWS). On June 

23, 2009, the FWS was asked to comment on any known 

threatened or endangered species within the project 

corridor. The agency responded on July 23, 

2009 (Appendix A). 

Based on correspondence with the FWS, TDEC, and 

Mississippi Department of Wildlife, Fisheries, and Parks 

(MDWFP), no federally-listed species (protected under the 

ESA) have been documented as occurring in Fayette 

County, Tennessee. Moreover, no federally or State listed 

species have been documented within one (1) mile of the 

project area. However, three State listed species, copper 

iris (Iris fulva), fatmucket (Lampsilis siliquoidea), and 

Southern hickorynut (Obovaria jacksoniana), have been 

Memphis Regional Intermodal Facility 3-114 

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3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-115 

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documented within four (4) miles of the project area (Table 

3-18).222 All correspondence is included in the Ecology 

Report. 

3.12.8.1 State-Listed Species within Four Miles of Project 

Iris fulva - Copper Iris

The State-listed threatened Copper Iris (Iris fulva) has 

been known to occur within four miles of the project area. 

The Copper Iris may be found in bottomland habitats.223

Although marginal habitat for this species is present within 

the project area, no individuals were observed during 

preliminary field surveys in April and June of 2009 at the 

actual project site. Therefore, this species is considered 

likely not present within the project area. No impacts to 

this species are expected as a result of the proposed 

project. 

Lampsilis siliquoidea – Fatmucket 

The Fatmucket (Lampsilis siliquoidea), which has been 

known to occur within four miles of the project area, is 

tracked by the State of Tennessee, but is not listed as 

Threatened or Endangered.224 This species occurs in 

slackwater with mud substrate within the Wolf River in west 

Tennessee.225 Potential impacts to this species could 

occur by sedimentation occurring as a result of the 

proposed project, but any such potential impacts would be 

prevented by implementing appropriate erosion and 

sediment control measures during construction. Therefore, 

no substantial impacts to this species are expected as a 

result of the proposed project. 

Obovaria jacksoniana – Southern Hickorynut 

The Southern Hickorynut (Obovaria jacksoniana), which 

has been known to occur within four miles of the project 

area, is tracked by the State of Tennessee, but is not 

listed as Threatened or Endangered.226 This species 

occurs in rivers with medium-sized gravel substrates and 

low to moderate current.227 This species could potentially 

be impacted by sedimentation occurring as a result of the 

proposed project, but this also would be prevented by 

 

222 http://www.state.tn.us/enviroment/na/pdf/county.pdf. 

223 TDEC Natural Heritage Program. Rare Species List by County, http://www.state.tn.us/environment/na/pdf/county.pdf. 

224 TDEC Division of Natural Areas. Correspondence dated June 24, 2009. 

225 TDEC Natural Heritage Program. Rare Species List by County, http://www.state.tn.us/environment/na/pdf/county.pdf. 

226 TDEC Division of Natural Areas. Correspondence dated June 24, 2009. 

227 TDEC Natural Heritage Program. Rare Species List by County., 

http://www.state.tn.us/environment/na/pdf/county.pdf. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

implementing appropriate erosion and sediment control 

measures during construction. Therefore, no substantial 

impacts to this species are expected as a result of the 

proposed project. 

Table 3-18: Rare, Threatened and Endangered Species Documented within 4 Miles 

of Project 

Common 

Name

Scientific 

Binomial 

TN 

Status

Federal 

Status 

State 

Rank Preferred Habitat Habitat Present? 

Copper Iris Iris fulva T N S2 

Bottomlands 

Fl: May-Jun 

Fr: Jun-Jul 

Yes 

Fatmucket Lampsilis 

siliquoidea N N S2 

Slackwater with mud 

subst; Wolf R (MS R 

Tributary); West TN 

No 

Southern 

Hickorynut 

Obovaria 

jacksoniana N N S1 

Rivers with mediumsized gravel substrates 

and low-mod. current; 

Wolf River; West TN 

No 

N – Not Listed 

T – Threatened species means any species or subspecies of plant which appears likely, within the 

foreseeable future, to become endangered throughout all or a substantial portion of its range in Tennessee. 

S1 – Extremely rare and critically imperiled in the State with five or fewer occurrences, or very few remaining 

individuals, or because of some special condition where the species is particularly vulnerable to extirpation 

from Tennessee. 

S2 – Very rare and imperiled within the State, six to twenty occurrences and less than 3000 individuals, or 

few remaining individuals, or because of some factor(s) making it vulnerable to extirpation from Tennessee.

3.12.8.2 Summary 

At this time, no Federal- or State-listed threatened or 

endangered species are known to occur within the specific 

project site, and no impacts are expected. Therefore, the 

proposed project is not expected to have an adverse effect 

on threatened or endangered species. Two State-tracked 

species occur within the project area; however, impacts 

would be avoided to these species by following proper 

erosion and sediment control measures during 

construction. 

Impacts associated with clearing and grubbing would not 

affect any plants of concern within the construction zone. 

To minimize sedimentation and runoff impacts, erosion and 

sediment control plans would be included in the project 

construction plans. TDOT’s Standard Specifications for 

Road and Bridge Construction, which includes erosion and 

sediment control standards for use during construction, will 

be implemented. 

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3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-117 

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The No-Build Alternative will not involve any impacts to 

Threatened or Endangered Species. 

3.12.9 Invasive Species 

Executive Order 13112 calls for the prevention of and 

control of invasive species (non-native exotics).228 EO 

13112 directs Federal agencies to not authorize, fund, or 

carry out actions that it believes are likely to cause or 

promote the introduction or spread of invasive species in 

the United States unless the agency has determined and 

made public its determination that the benefits of such 

actions clearly outweigh the potential harm caused by 

invasive species; and that all feasible and prudent 

measures to minimize risk of harm will be taken in 

conjunction with the actions. 

The guidelines of EO 13112 will be adhered to while 

constructing and maintaining the project in an attempt to 

control and prevent the spread of any invasive exotic 

species to the project site. NSR will be required to use 

invasive-free seed mixtures and re-vegetate with native 

plant species only. 

The No-Build Alternative would not be expected to alter 

conditions at the site concerning invasive species. 

3.12.10 Wild and Scenic River 

The National Wild and Scenic Rivers System (NWSRS) 

was created by Congress in 1968229 to preserve rivers 

with outstanding natural, cultural, and recreational values 

in a free-flowing condition for the enjoyment of present and 

future generations. 

There are no watercourses or rivers listed on the NWSRS 

or in Nationwide Inventory of Rivers for potential inclusion 

in the NWSRS within the project area of the Build 

Alternative 1. 

The No-Build Alternative has no effect on any watercourse 

listed on the NWSRS. 

3.12.11 Exceptional Tennessee Waters or Outstanding 

National Resource Waters 

Exceptional Tennessee Waters (ETW, previously known 

as Tier 2) and Outstanding National Resource Waters (Tier 

3) have been designated to implement the Tennessee’s 

anti-degradation policy. In general, these include 

 

228 See EO 13112, Invasive Species, 64 Fed. Reg. 6183 (February 3, 1999). 

229 Public Law 90-542; 16 U.S.C. 1271 et seq. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-118 

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waterbodies with good water quality, important ecological 

values, valuable recreational uses, and outstanding 

scenery.230

Build Alternative 1 would have no effect on any 

watercourse listed as an ETW or ONRW as none are 

contained in the project area. 

The No-Build Alternative has no effect on any watercourse 

listed on the ETW or ONRW. 

3.12.12 Environmental Permits 

Alterations to streams or other aquatic sites designated as 

Waters of the State or Waters of the U.S. require either 

individual or general Aquatic Resource Alteration Permits 

(ARAP)231 from the State of Tennessee, Individual or 

Nationwide 404 USACE permits, and, where applicable, a 

Tennessee Valley Authority (TVA) 26a permit or letter of 

no objection. 

Section 26a of that TVA Act of 1933232 requires that TVA 

approval be obtained before any construction activities can 

be carried out that affect navigation, flood control, or public 

lands along the shoreline of the TVA reservoirs or in the 

Tennessee River or its tributaries. The project area does 

not lie along a TVA reservoir, the Tennessee River, or its 

tributaries. Therefore, a TVA Section 26a permit is not 

required for the proposed project. 

All wetland impacts require confirmation by, and 

coordination with, permitting agencies. All require either 

general or individual ARAP permits from the State of 

Tennessee. Almost all require either Nationwide or 

Individual permits from the USACE pursuant to Section 

404 of the CWA. Other agencies such as the FWS and 

EPA may be involved in the permitting process. 

Wetland impacts which are subject to both State or Federal 

jurisdiction, and which do not meet criteria for either 

general or Nationwide permits require Individual permits. 

These typically require compensatory mitigation for 

impacts. 

 

230 TDEC, “The Known Exceptional Tennessee Waters and Outstanding National Resource Waters,” http://environmentonline.state.tn.us:7654/pls/enf_reports/f?p=9034:34304:4367000856339681. 

231 "Aquatic Resource Alteration Permit" means a permit pursuant to §69-3-108 of the Tennessee Water Quality Control 

Act of 1977, which authorizes the alteration of properties of waters of the State which result from activities other than 

discharges of wastewater through a pipe, ditch or other conveyance (CHAPTER 1200-4-7).

232 48 Stat. 58-59, 16 U.S.C. sec. 831. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-119 

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Construction projects disturbing one or more acres of land 

require stormwater control permits issued by the State of 

Tennessee pursuant to the NPDES. For any project that 

affects water flowing into an open sinkhole or cave, or for 

any impact that may affect the groundwater via a sinkhole, 

a Class V Injection Well Permit may be required.233

Various industrial stormwater NPDES permits would be 

required to operate the facility. Compliance with these and 

any other permit requirements would be identified further in 

the project development process. 

FRA, FHWA, and TDOT would carry out further 

coordination with regulatory agencies before preparing 

mitigation plans and submitting permit applications. Permit 

requirements and mitigation plans will be based on these 

discussions.

NSR would be required to apply for State and Federal 

environmental permits after appropriate technical studies 

have been completed. The following permits would be 

required for the proposed project: 

(1) USACE Individual or Nationwide Permit for 

Impacts to Waters of the U.S. (including 

wetlands and aquatic resources). 

(2) ARAP (TDEC) for Construction and Removal of 

Minor Road Crossings. 

(3) ARAP (TDEC) - General Permit for Minor 

Alterations to Wetlands. 

(4) NPDES Stormwater Individual Permit for 

Construction. 

(5) NPDES Construction General Permit (if needed). 

The No-Build Alternative would not necessitate the 

acquisition of any State and Federal permits. 

3.13. Geological and Soil Impacts 

3.13.1 Geology 

The project is located in the Coastal Plain physiographic 

unit province of Western Tennessee. Based on the 

published geological information, the near-surface mapped 

geologic unit belongs to the Tertiary age Claiborne group 

 

233 Rules of the Tennessee Department of Environment and Conservation, Division of Water Supply, Rules of Water 

Quality Control Board Chapter 1200-4-6, Underground Injection Control. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-120 

6/30/2010 

specifically the Memphis Sand. This formation generally 

includes unconsolidated combinations of sand, silt, and 

clay, extending to great depths. Typically, an unmapped, 

thin mantel of Quaternary age loessial soils or clays and/or 

stream terrace deposits of sand/silt/clay would overlie the 

primary geologic unit. Thin lenses of lignite can be 

present.234 

Reportedly, the site is underlain by the recharge area for 

the Memphis Sand Aquifer, Figure 3-24. The Memphis 

Sand should not affect general grading or facility 

construction except that flatter slope inclinations could be 

required for stability and erosion controls. 

The No-Build Alternative would have no impact to the area 

geology. 

3.13.2 Soils 

Based on the USDA Soil Survey of Fayette County, 

Tennessee, the site appears to contain three general types 

of soils: Collins silt loam (map unit Co), Grenada silt loam 

(map unit GaB2) and Lexington-Ruston complex (map unit 

LeF). 

 The Collins series are moderately well drained, 

nearly level, acid soils that are on bottomlands and 

along narrow drainage-ways. These soils consist of 

recently deposited silt and sandy alluvium. The 

surface layer of Collins soils is brown silt loam to 

brown fine sandy loam. The subsoil is brown silt 

loam to brown fine sandy loam mottled with gray. In 

many places a layer of recently deposited alluvium, 

14 to 36 inches thick, overlies an older, poorly 

drained soil. 

 The Grenada Series consists of deep, moderately 

well drained, level to strongly sloping soils on 

uplands and terraces that range from 2 to 5 percent. 

Many of the members are eroded to severely eroded. 

These soils are formed in thick loess. The surface 

layer is brown silt loam, and the subsoil is brown or 

yellowish-brown silt loam or silty clay loam. The pan 

layer is mottled gray and brown. It occurs at a depth 

of about 24 inches and is 1 to 5 feet thick. 

 The Lexington series consists of deep, well-drained, 

nearly level to strongly sloping soils that are on 

narrow ridge tops and side slopes that range from 2 

 

234 Burns Cooley Dennis, Inc., December 17, 2009, Geotechnical Investigation SR-57 Bridge and Approach Over Norfolk 

Southern Rail Line, Rossville, TN, Report to AECOM. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-121 

6/30/2010 

to 12 percent. These soils are formed in loess that is 

less than 42 inches thick and is underlain by sandy 

material of the Coastal Plain. The surface layer is 

brown silt loam, and the subsoil is reddish-brown to 

yellowish-red silty clay loam. 

3.13.3 Geologic Hazards 

Published geological information from the TDEC indicated 

that Fayette County does not contain any karstic or 

’sinkhole’ environmental hazards. 

Based on the site topography, significant landslides are not 

of concern for this area. Some minor, shallow sloughing 

associated with stream erosion could be possible in any 

local branch channels in this region. 

The regional soils do not indicate any subsurface concerns 

related to corrosive or collapsible soil conditions. Some 

areas in the region with loessial deposition have indicated 

a potential for dispersive soil conditions, but due to the 

project parameters and physical conditions of the site soils 

encountered, this is not considered a critical design 

concern at this site. There exist a potential of surface 

erosion during heavy rain events, but it’s considered a 

typical soil condition for this region and not of specific of 

inordinate concern for the project site soils encountered. 

The site is within the defined footprint (over 2,200 square 

miles in west Tennessee alone) for the Memphis Sands 

aquifer recharge zone. Precautions would be taken to 

prevent contaminants from entering the aquifer. 

3.13.4 Seismic 

Rossville, Fayette County, is located within an area 

affected by the New Madrid seismic zone. No specific 

active faults are identified in the project area.235 

Geotechnical design parameters for the site should be 

obtained from the respective technical reports. 

3.13.5 Geologic or Soil Impacts 

Construction of the Memphis Regional IMF would require 

land-disturbing activities to approximately 440 acres of 

land, which would increase the potential for long-term and 

temporary impacts to the topography and soils in the 

project area. 

Potential temporary impacts include soil compaction and 

erosion. Movement of construction equipment could cause 

 

235 Burns Cooley Dennis, Inc., December 17, 2009, Geotechnical Investigation SR-57 Bridge. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

excessive soil compaction, which could result in restricted 

water penetration, restricted vegetation root development, 

and reduced oxygen diffusion rates. Outside of the 

planned footprint of the operating yard and tracks, the 

potential for excessive soil compaction would be minimized 

through limiting the duration of construction to the greatest 

extent practicable, decreasing the frequency of 

construction equipment traffic in areas that would not be 

paved, and decreasing construction traffic in areas with 

soils that are susceptible to compaction. Severely 

compacted areas that would be revegetated would be 

mitigated through plowing or tilling to loosen the soils prior 

to revegetation efforts. Soil erosion would be mitigated 

through temporary erosion and sedimentation control 

measures during construction and implementation of 

permanent measures, such as revegetation, following 

construction. 

Potential geological impacts include contamination 

entering the Memphis Sand aquifer within the recharge 

areas. Any project, within the over 2,200 square miles 

recharge zone in west Tennessee, should manage surface 

runoff and protect underground water sources. Planned 

mitigation measures are discussed in Section 3.12.6 

Aquifer Impacts and Section 3.12.7 Stormwater Impacts. 

For surface water these measures include lined-storm 

water detention basins with outlet structures that can be 

closed to stop any contaminated stormwater from reaching 

the stream in the unlikely event that a release occurs. In 

addition, the stormwater system would be design to mimic 

pre-development hydrology and minimize initial flow rates 

following rain events and decrease resultant peak flows. 

For underground water sources, such as any exposed 

Memphis Sands, measures include lining or covering with 

at least a 12-inch thick layer of compacted clayey material, 

preferably a low plasticity clay (CL) or high plasticity clay 

(CH) material. To insure positive flow of any exposed 

underground water, temporary and/or permanent ditches, 

culverts, and/or under-drains would be installed to provide 

positive drainage across the site. 

For Build Alternative 1, the only impacts to the soils are 

expected to be constructability type issues related to 

compaction and permanent slope inclinations. 

The No-Build Alternative would have no effect on the soils 

occurring within the boundaries of the project. 

Memphis Regional Intermodal Facility 3-122 

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3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

3.14. Visual Impacts 

3.14.1 Existing Visual Environment 

The visual landscape within the project area can be 

divided into the following: 

 Hilly pasture, 

 Forested areas, 

 Scattered residential development, and 

 Commercial and industrial development. 

Viewers would be those able to see the Memphis Regional 

IMF or lead tracks from adjacent properties, along SR-57, 

or from within the facility itself, Photo 3-9. Some 

commercial and industrial businesses are located on SR57. Persons or groups of persons with a view of the 

proposed Memphis Regional IMF include residents of 

adjacent properties, travelers on SR-57, and employees 

and customers of commercial and industrial businesses in 

the vicinity. Views of the proposed project area vary from 

unrestricted to restricted, depending on the surrounding 

vegetation, terrain, and placement of buildings and track. 

Fayette and Marshall Counties do not have comprehensive 

plans, transportation plans, or development regulations 

that contain guidelines or recommendations to limit the 

visual impacts of development. Interviews with local 

officials and reviews of planning maps indicate no 

identified scenic areas or recognized areas of beauty in the 

project area. 

3.14.2 Visual Impacts 

The project would introduce a new commercial facility, 

railroad track, and overpass into the viewshed. The light 

poles (70 feet tall) and cranes (approximately 40 feet tall) 

used to load and unload freight cars would potentially be 

visible offsite from the east side of Neville Road and from 

the new SR-57 overpass. The new SR-57 overpass would 

be visible to travelers on SR-57 and local businesses and 

residences along SR-57 

Some residents on the east side of Neville Road, as well 

as travelers on SR-57 and businesses along SR-57, would 

have a view of the lead tracks, Photo 3-10. Forested areas 

along the eastern and southern sides of Neville Road 

would provide some screening. Topography would visually 

Memphis Regional Intermodal Facility 3-123 

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3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-124 

6/30/2010 

shield some nearby residents from the Memphis Regional 

IMF. 

Due to topography, construction of the Memphis Regional 

IMF would require up to a 40-foot cut slope on the eastern 

side of the site. Along this eastern edge of the facility a 

10-foot differential would be maintained between the 

existing ground and top of rail. This would limit the 

potential visual impacts for residents and travelers on Knox 

Road. In addition, the west side of Knox Road is forested 

and would screen views of the Memphis Regional IMF, 

Photo 3-11. 

Following a review of these viewsheds (and noise 

impacts), NSR modified its proposed preliminary design to 

voluntarily include earthen berms along parts of the 

western and east sides of the facility and along a section of 

the west side of the lead tracks.236 The berms along with 

the current topography and vegetation would break the 

potential line of sight for nearby residents. 

Lighting at the Memphis Regional IMF is required for 

security, safety and operations.237 Lighting would consist 

of shielded directional lighting (i.e., shine/point downward) 

designed to reduce glare effects or ambient light to the 

adjacent properties, minimizing the potential for light 

pollution.238 Pole-mounted fixtures would also be set at 

the lowest height possible to achieve the required level of 

illumination. Within the operating yard, the lighting plan 

(Figure 3-28) would reduce the pole-mounted fixture height 

from the 100-foot NSR standard to 70 feet tall. 

At other locations within the IMF, the standard 40-foot tall 

street lights would be used. The goal of these measures 

would be to avoid or minimize light pollution or trespass 

where light, direct or reflected, spills beyond the boundary 

of the intended illuminated subject area where it is not 

desired or required.239 

Lighting fixtures (as shown in Figure 3-28) would produce 

illumination level not exceeding 0.5 foot candles along the 

project boundary. Average light levels for the majority of 

the facility would be less than 2 foot candles except for the 

maintenance pad and entrance area, which would be lit to 

 

236 Due to property issues, NSR would not be able to construct the berm on the west side of the lead tracks until after 

October 2010. 

237 NSR considered Dark Sky measures to reduce light pollution by changes in lighting practices, education, and light 

mitigation. 

238 International Dark-Sky Association, "Statement on Outdoor Lighting Energy Legislation," July 2009. 

239 Lighting Research Center, Rensselaer Polytechnic Institute, "Lighting Answers," February 2007 

http://www.lrc.rpi.edu/programs/nlpip/lightinganswers/lightpollution/lightTrespass.asp
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-125 

6/30/2010 

an average of 5 foot candles.240 By comparison a typical 

parking lot at night registers 5 to 10 foot candles, and a 

night ballgame registers 50 to 100 foot candles. Daylight 

equals 10,000 foot candles.241 

Figure 3-28: Tentative Lighting Plan for Memphis Regional IMF

The existing vegetation, consisting mainly of grass and 

trees, within the disturb limits of the project site would be 

lost. Between the project limits and the clearing limits, 210 

acres of vegetation would be left undisturbed. The 60 

acres outside of the facility, which would be disturbed 

during construction, would be re-vegetated with grasses, 

native flora, and evergreen trees. The old and new 

vegetation would reduce the visual impacts from the 

facility. The main part of the Memphis Regional IMF would 

be designed as a relatively flat parking lot formed by a cut 

slope on the eastern edge of the facility and a fill along the 

western edge of the facility. 

To be able to operate the facility safely, the site would be 

graded to create a plateau for constructing a facility 

consisting of level tracks for rail cars to be placed for 

unloading and unloading of containers and trailers. To 

create the plateau, the majority of the eastern side of the 

facility would be in a cut that ranges up to 40-foot deep in 

 

240 A foot candle is a unit of luminance or light intensity. The unit is defined as the amount of illumination the inside 

surface of a 1-foot radius sphere would be receiving from a uniform light point source. 

241 Paul Schlyter, Radiometry and Photometry in Astronomy FAQ (2006). 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-126 

6/30/2010 

places. The western side of the facility would be 

constructed on a fill. Along the eastern and western 

boundary of the facility, where there is less than 10-foot in 

depth, NSR proposes to construct a landscape berm 

where the top of the berm would be 10-foot higher than the 

top of pavement adjacent to the berm. Also along the 

western edge of the proposed lead adjacent to the 

residents along Neville Road, NSR is volunteering to 

construct a landscape berm where the top of the berm 

would be approximately 15-foot higher than the adjacent 

top of rail.242 These features should reduce the visual and 

noise impacts from the facility. 

No areas of high visual quality or visually sensitive 

resources exist in the area. The visual setting along SR-57 

has already been disrupted by the construction of 

commercial and industrial facilities. The visual impact to 

residents, businesses, and travelers in the area would not 

be adverse. 

Under the No-Build Alternative, no activities would occur 

related to the proposed Memphis IMF and there would be 

no visual impacts. 

3.15. Energy Impacts 

The energy expected to be used by Build Alternative 1 is 

summarized below. 

3.15.1 Construction 

Energy consumption would result from activities related to 

site preparation and construction of the facility, lead tracks, 

SR-57 overpass, the loop track, and Industrial Road. It is 

anticipated that the main energy source for these activities 

would be diesel fuel. Also, energy consumption would 

occur related to the manufacturing and transport of the 

construction components and by the heavy equipment 

used for facility. 

Temporary traffic delays in Tennessee could occur on SR57 during construction of the overpass. Adding turning 

lanes to US Hwy 72 could cause temporary traffic delays in 

Mississippi. These delays could result in temporary, 

insignificant increases in energy use including gasoline 

and diesel fuel. 

 

242 Due to property issues, NSR would not be able to construct a berm on the west side of the lead tracks until after 

October 2010. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

Memphis Regional Intermodal Facility 3-127 

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3.15.2 Facility Infrastructure and Operations 

A major design feature of Build Alternative 1 is the 

construction of a loop track at the south end of the facility to 

facilitate train movements into and out of the IMF. If the 

facility design had not included a loop track, additional 

switching would be required. This additional operating time 

would increase energy consumption as well as potential 

noise and air quality impacts. 

Operational energy impacts would be reduced by 

implementation of energy conservation measures and use 

of energy efficient technologies. In December 2009, NSR 

became the first large railroad in the nation to join the U.S. 

Green Building Council, a Washington based nonprofit 

dedicated to promoting cost-efficient and energy-saving 

buildings.243 To increase energy efficiency, the 

administrative building is being designed for submission as 

a LEED Green Building Rating System certified 

building.244 

t and to use Tier 4 

technology for the overhead lift cranes. 

ngines, and trucks use diesel fuel as 

their energy source. 

 

During operation of the IMF, much of the site would be 

powered by electricity. Electricity would be required for 

lighting of the IMF operations during the night; control of 

gates; and normal administrative building functions (such 

as lighting, heating, computer, and telecommunications 

facilities). Operational energy impacts would be reduced 

by implementation of energy conservation measures and 

use of energy efficient technologies. Facility equipment 

such as cranes and switch engines would use diesel fuel. 

NSR has committed to use ultra low-sulfur transportation 

grade diesel fuel (0.0015 percent sulfur) for NSR 

containers and trailer handling equipmen

3.15.3 Train and Truck Use 

Freight trains, switch e

Under Build Alternative 1, fuel savings would be realized in 

the long term due to higher efficiencies in the movement of 

freight on rail versus highway trucks. Nationwide, 23.8 

million gallons of fuel are estimated to be saved on an 

annual basis from the projected conversion of 187,000 

truckloads from highway to rail between the new Memphis 

Regional IMF and Northeastern regions of the U.S.245 An 

estimated 186 million loaded truck vehicle miles per year 

243 Worldnews.com, “Norfolk Southern joins Green Building Council”, December 8, 2009. 

244 Worldnews.com, “Norfolk Southern joins Green Building Council”, December 8, 2009. 

245 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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on highways between Memphis and the Northeast U.S. are 

projected to be eliminated by the project, which is 

anticipated to contribute to safety and relieve highway 

congestion.246

 to the reduction in truck traffic for freight 

shipment. 

ever, the long-term energy savings 

would also not occur. 

 Special Projects 

Administration (RSPA), and the FRA. 

investigation: hazardous waste materials, aboveground 

 

In summary, a substantial amount of energy would be 

required to construct the facility but these energy uses are 

temporary in nature. Once operating, the Memphis 

Regional IMF would require modest energy usage but 

would lead to substantially reduced energy costs overall 

primarily due

Under the No-Build Alternative, the short-term energy uses 

would not occur. How

3.16. Hazardous Materials Impacts 

This section discusses hazardous materials as related to 

the property for Build Alternative 1 and the types of 

materials that may pass through the site via intermodal 

traffic. Hazardous materials are substances that have, or 

would have when combined with other materials, a harmful 

effect on humans or the natural environment. Stationary 

hazardous materials are primarily regulated under the 

Resource Conservation and Recovery Act (RCRA) of 

1976, as amended; the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) of 

1980; and the Superfund Amendments and 

Reauthorization Act (SARA) of 1986. Hazardous materials 

in transit are those identified under comprehensive 

hazardous materials transportation laws247 and DOT 

regulations248 administered through the Pipeline and 

Hazardous Materials Safety Administration (PHMSA), 

formerly part of the Research and

3.16.1 Potential Hazardous Material Sites 

A Phase I Environmental Site Assessment was conducted 

for the project site in 2009 in general accordance with 

Guidance Document E-1527-05 per the American Society 

for Testing and Materials International (ASTM), Standards 

on Environmental Site Assessments for Commercial Real 

Estate.249 The following concerns were the subject of the 

246 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 

247 49 U.S.C. 5101 et seq. 

248 49 C.F.R. Parts 171-180. 

249 AMEC, PHASE I ESA, November 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

and underground storage tanks, landfills, dumps, spill 

sites, or other chemical, physical, or biological hazards. 

In addition, an environmental database search was 

conducted on April 21, 2009. The resulting Environmental 

Data Report did not identify any potential hazardous 

materials or petroleum contamination sites within the 

proposed project corridor that are listed in Federal or State 

databases. 

One National Priorities List (NPL) site, Ross Metals, was 

identified approximately 0.8 miles east-northeast of the 

Memphis Regional IMF site. The Ross Metals site is 

located at 100 North Rail Road Street in Rossville. From 

1978 to 1992, Ross Metals operated a secondary lead 

smelter at the site. It received spent lead acid batteries, 

lead oxide, scrap metal, and other lead waste and material. 

Blast furnace slag was managed on site in a landfill. 

Wastewater and runoff was collected in the northeast 

corner of the Ross Metals facility and discharged into a 

wetland area. The EPA conducted a removal option at the 

site. The Ross Metals property is not anticipated to have 

caused a recognized environmental condition on Build 

Alternative 1 site due to its distance away and the 

anticipated groundwater flow direction away from the Ross 

Metals site toward the Wolf River.

3.16.2 Potential Hazardous Material in Transit 

At this time, traffic along the NSR mainline in the Rossville 

area includes about 18 trains per 24 hour period (about 

nine trains each direction). About four of those trains (2 

each direction) are intermodal trains. When the Memphis 

Regional IMF becomes fully operational, NSR expects the 

new intermodal traffic to be approximately four westbound 

trains terminating and four eastbound trains originating 

each day (eight intermodal trains movements). Two of 

these intermodal train movements would have previously 

traveled to the Forrest IMF in Memphis. The net result 

would be an increase of a predicted 6-7 intermodal trains 

on the NSR mainline east of the proposed IMF and a 

reduction of 1-2 intermodal trains on the mainline west of 

the IMF each day. These new trains would enter and exit 

the facility on a daily basis. Intermodal trains that enter the 

facility would carry containers and trailers. Examples of 

commodities in the container and trailer shipments 

transferred between trucks and trains at the IMFs include: 

electronics, mail, toys, paper products, clothes, appliances, 

textiles, and auto parts (Figure 3-29). Only 3 to 4 percent 

of the intermodal shipments currently transported by NSR 

Memphis Regional Intermodal Facility 3-129 

6/30/2010 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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contain commodities that are considered hazardous 

materials.250

Figure 3-29: What Moves in Intermodal Containers/Trailers 

Federal hazardous materials transportation laws and 

regulations limit freight that can and cannot be shipped 

through intermodal service. Before freight is accepted for 

transport, shippers of hazardous materials are required by 

Federal law to classify the material, describe the material 

in shipping papers, meet DOT packaging requirements, 

ensure the freight is marked and labeled as required, and 

ensure that the freight is in proper condition for 

transportation. Federal regulations specify packaging and 

container requirements. Containers and trailers hauling 

hazardous materials would remain sealed during their 

movement through the facility boundaries. 

DOT’s list of materials considered hazardous includes 

items such as paint, liquids that are flammable or 

corrosive, batteries, materials under pressure such as 

gases and fire extinguishing equipment, auto parts 

including air bags, as well as the types of materials more 

 

250 Under comprehensive hazardous materials transportation laws (e.g. 49 U.S.C. 5101 et seq.) and DOT regulations, 49 

C.F.R. parts 171-180, administered through the Pipeline and Hazardous Materials Safety Administration (PHMSA) and 

Research and Special Projects Administration (RSPA), and the Federal Railroad Administration (FRA). 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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traditionally considered hazardous and found in DOT’s 

list.251 

Most of the containers that would be transported through 

the Memphis Regional IMF would not contain materials in 

quantities that would cause a release off of the Memphis 

Regional IMF site if a container were damaged. DOT 

container, packaging, packing, and handling requirements 

would reduce the likelihood of a release. Spills of 

transported hazardous materials on intermodal facilities 

are rare, but if a leak or spill would occur on-site, trained 

IMF staff would quickly respond to contain, manage 

recovery, and clean up the spill. 

Certain hazardous commodities are strictly forbidden from 

intermodal shipment. “Forbidden” commodities are never 

accepted for transportation through intermodal containers 

by NSR or its railroad subsidiaries.252 Such “forbidden” 

commodities include: 

 Toxic inhalation hazards (TIH) 

 Asbestos of any form 

 Class 7 radioactive materials (except small items 

such as watch dials) 

 Division 4.2 spontaneously combustible 

materials, including sodium dithionite and sodium 

hydrosulfite 

 Temperature controlled organic peroxides 

(Division 5.2) 

 Medical wastes/infectious substances 

 Explosives (Division 1.1, 1.2, or 1.3) 

 Batteries for reclamation of material 

Petroleum products and equipment fluids necessary for the 

facility’s operations would normally be present at the 

maintenance area. In addition, the line-haul and switch 

locomotives would be refueled by truck. The maintenance 

and refueling areas are designed to provide secondary 

containment and other measures to protect against release 

and threat to human health or the environment, in 

 

251 40 C.F.R. § 172.101. 

252 NSR, Background on Norfolk Southern Intermodal Items Considered Hazardous Commodities, March 8, 2008. NSR, 

Intermodal Rules Circular #2, November 8, 2000 (Updated February 5, 2009), 

http://www.nscorp.com/nscintermodal/Intermodal/Rules_Circular/intermodal_rules_circular.pdf.
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accordance with State and Federal environmental 

regulatory requirements pertaining to the handling of such 

materials. 

3.16.3 Potential Hazardous Material Impacts 

With respect to the property proposed for the Memphis

Regional IMF, no recognized environmental conditions or

potential sources of hazardous materials were located in/or 

adjacent to the site. One small area in the south-central 

portion of the project area was identified as containing a 

moderate amount of old bulldozer parts and metal debris. 

Another small area where the lead tracks would be located 

appeared to contain household solid waste. The metal 

debris and the household solid waste would be removed 

and recycled or disposed in accordance with Federal and 

State requirements during construction. 

In the event hazardous substances/wastes are 

encountered within the proposed project site, their 

disposition shall be subject to the applicable sections of 

the Federal Resource Conservation and Recovery Act, as 

amended; and the CERCLA, as amended; and the 

Tennessee Hazardous Waste Management Act of 1983.253 

With respect to the transport of hazardous materials, 

certain commodities are prohibited from being transported 

through an IMF, such as toxic inhalation hazards (e.g., 

chlorine gas), radioactive materials, asbestos and 

explosive materials. Many items, however, that could be 

considered hazardous are commonly found in household 

items, such as paints, lubricants, fertilizers, and cleaners. 

On an annual basis, NSR typically transports 

approximately 2.2 to 2.7 million shipments or containers 

through their existing IMFs across the eastern United 

States, of which only 3 to 4 percent contain hazardous 

materials.254 During the period 2004 through 2009, NSR 

intermodal transported 16,070,989 intermodal units. 

During that same time there were 25 spills from intermodal 

units inside IMFs, or 0.000156% for each shipment. 

Additionally, the trend has been toward fewer spills each 

year (2004-10, 2005-5, 2006-2, 200704, 2008-1 and 2009-

3). Of these 25 spills, 17 were one gallon or less in size 

and only one spill was over 25 gallons. NSR owns and 

operates 27 different intermodal facilities.255 IMF 

personnel are trained and would take immediate action 

 

253 42 U.S.C. 6901 et seq; 42 U.S.C 9601 et seq; Tennessee Code Annotated (T.C.A.) 68-212-101 et seq.

254 NS Technical Memo, Subject Memphis Regional Intermodal Facility – HazMat Traffic, dated January 15, 2010. 

255 NSR Intermodal operation records. 
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upon noticing a spill and have contact information to bring 

in specialized vendors to contain and remove any leaked 

material. The IMF would be designed with a shutoff valve 

in the drainage system to ensure that any leaked material 

does not leave the facility. The Memphis Regional IMF 

would be designed such that any fluid materials which 

leave the large concrete pad are directed to a detention 

basin with a temporary holding capacity in excess of 30 

acre-feet and which would be equipped with emergency 

valves and gates to prevent materials from leaving the site. 

The potential risks of adverse impacts from releases from 

such shipments are considered to be very low because: 

 Low percentage of shipments containing 

hazardous materials, 

 Prohibitions on the most hazardous commodities, 

 NSR’s commitment to safety and recognized past 

track record of intermodal facility safety, 

 DOT shipping and packaging requirements noted 

previously, and 

 Low incidence of even very minor releases of 

transported hazardous commodities in an IMF. 

It is not anticipated that the proposed facility would have 

materials triggering the inventory provisions of Federal 

laws such as the Emergency Planning and Community 

Right-to-Know Act (EPCRA)256, but all applicable 

emergency response protocols and notifications would be 

implemented in case of a release event. 

The operation of the Memphis Regional IMF would utilize 

small amounts of materials considered hazardous, 

primarily fueling and lubrication materials for on-site 

equipment. Maintenance and fueling activities from IMF 

equipment would occur within the maintenance pad area. 

Included in this area would be five (5) ASTs ranging in size 

from 300 to 3,000 gallons. The larger AST would be for 

storage of diesel fuel. The other four (4) ASTs would hold 

gasoline, 40W motor oil, anti freeze, transmission oil, used 

oil, and hydraulic oil. Per EPA regulations, the ASTs are 

required to have secondary containment adequate to 

contain the full amount of the tank contents, applicable 

inspection, testing and spill detection measures as 

included in AST management.257 In accordance with the 

 

256 42 U.S.C. § 11001 et seq. 

257 40 C.F.R. Part 112 
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Spill Prevention, Control and Countermeasures Program 

(SPCCP) developed by EPA, facility drainage is designed 

to capture and contain any releases. Additionally, the 

stormwater from the maintenance pad would be treated 

with an oil-water separator. The pollutants would be 

disposed of through the Rossville sewer system. The 

remaining stormwater would be discharged into a BioTreatment Pond. The only fueling, which would not occur 

on the maintenance pad, is limited to locomotives. The 

IMF does not include locomotive maintenance or 

permanent fueling facilities. 

Any petroleum or hazardous materials needed for facility 

operations would be handled and used in accordance with 

package labels and manufacturer’s directions. Wastes 

would be segregated, labeled, and stored in a manner that 

would prevent the release of hazardous constituents into 

the environment. 

In addition, the IMF and its employees are subject to the 

United States Hazardous Materials Instructions for Rail, 

which are operating rules that implement certain portions 

of 49 CFR Part 172 and include emergency response. 

Under facility response protocols, facility employees, 

working with NSR environmental staff and local emergency 

first responders as necessary, have around-the-clock 

access to emergency response resources (local first 

responders, local environmental contractors, EPA, and 

USACE) accessible through a telephone call to the NSR 

Tennessee Division dispatch office, which is staffed 24 

hours a day, 7 days a week. NSR also has published a 

Railroad Emergency Response Planning Guide, which is 

available to local first responders. 

In the unlikely event of a hazardous material spill, 

emergency protocols (site specific spill prevention control 

and countermeasure (SPCC) plan for response and 

recovery would go into immediate effect and a variety of 

emergency response resources are available as 

necessary, including facility personnel, local, state and 

federal emergency responders as well as emergency 

response contractor resources. Emergency protocols for 

the IMF will provide for certified and trained employees 

onsite to handle any hazardous materials release or 

emergency spill response. Additionally, under facility 

response protocols, facility employees, working with NSR 

environmental staff and local emergency first responders 

as necessary, have around the clock access to emergency 

response resources accessible through a telephone call to 

the dispatch office which is staffed 24 hours a day, 7 days 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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a week, to handle any release or spill of hazardous 

materials. 

The facility would also be governed by NSR’s Emergency 

Response Guide to Railroad Incidents and its divisional 

emergency action plan and SPCC plan, which specify 

response protocols and notifications. In addition, 

guidelines established by nationally recognized bodies 

(such as EPA, PHMSA, OSHA, and DOT) assist 

emergency response service organizations. For 

transportation incidents, detailed procedures are found in 

the 2008 Emergency Response Guidebook.258 The 2008 

Emergency Response Guidebook provides emergency 

detailed procedures for a variety of types of spills and 

releases. 

No potential hazardous material sites would be impacted 

by Build Alternative 1. Also, given NSR’s safety record, 

DOT’s comprehensive regulatory program governing 

hazardous materials shipments, emergency response 

planning and preparedness measures noted above, and 

the facility design, Build Alternative 1 would be expected to 

have low potential for impact to the natural or human 

environment due to hazardous material transport through 

the facility. 

Based upon historical information on releases or spills at 

IMFs, any release or spill that would occur would be a 

small volume and be contained upon the concrete pad 

where IMF containers are temporarily stored. The 

Memphis Regional IMF is designed such that any fluid 

materials that leave the large concrete pad are directed to 

multiple retention basins, which are equipped with 

emergency valves and gates to prevent materials from 

leaving the Memphis Regional IMF facility. With the 

emergency response training of on-site personnel, the 

availability of additional response personnel on an around 

the clock basis, the protocols established for local 

emergency response and the notification provisions for 

additional emergency response resources, the proposed 

Memphis Regional IMF would achieve a very high level of 

safety and protection from hazardous materials releases or 

spills. 

The No-Build Alternative would not be expected to impact 

any hazardous materials nor would such materials be 

transported to the site. Shipments would however, 

continue along the mainline tracks north of the site. 

 

258 DOT 2008. 
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3.17. Pedestrian and Bicycle Impacts 

TDOT’s bicycle and pedestrian policy, as stated in the 

Bicycle and Pedestrian element of the Tennessee LongRange Transportation Plan, includes provisions for bicycle 

and pedestrians in new construction and reconstruction of 

roadway projects through design features appropriate for 

the context and function of the transportation facility. The 

policy also identifies existing and proposed bicycle routes. 

SR-57 in the project area is not currently on the State list of 

existing or proposed bicycle routes. 

No dedicated bicycle or pedestrian facilities exist in the 

project area. The project area is currently agricultural land. 

The existing shoulder width along SR-57 within the project 

area varies from 0 to 2 feet. Currently, the only dedicated 

pedestrian facilities or sidewalks exist in the nearby towns 

of Rossville and Piperton. No dedicated bicycle facilities 

exist in these towns. Fayette County and the towns of 

Rossville and Piperton do not have comprehensive bicycle 

and pedestrian plans and do not address bicycle and 

pedestrian facilities in other planning documents. 

Under Section 1202(a) of the Transportation Efficiency Act 

for the 21st Century (TEA-21) and 23 U.S.C. § 109(n), 

TDOT considered the need to provide bicycle and 

pedestrian facilities. No bicycle or pedestrian facilities 

would be appropriate for the Memphis Regional IMF site or 

the lead tracks area. 

The proposed SR-57 overpass would have paved 10-foot 

shoulders that would accommodate pedestrians and 

bicyclists. Currently, no plans exist to add sidewalks or 

pedestrian facilities along SR-57 in the project area. Build 

Alternative 1 would have a minor positive benefit to longterm pedestrian and bicycle use on SR-57 is anticipated 

due to inclusion of improved shoulder width on the 

overpass. 

Due to the commercial nature of Industrial Road and the 

fact that it dead-ends within the restricted access IMF, 

there are no plans to include pedestrian or bicycle paths 

along this road. 

The No-Build Alternative would not change the existing 

roadway network for bicyclists and pedestrians. 

3.18. Indirect and Cumulative Impacts 

Sections 3.1 through 3.17 describe the project’s 

anticipated direct effects associated with Build Alternative 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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1. This section presents a discussion of the potential 

indirect and cumulative impacts. 

The indirect (secondary)259 and cumulative effects 

associated with the proposed Memphis Regional IMF

development are presented as below for each of the 

resource areas. 

Indirect (secondary) effects are caused by an action (such 

as the proposed Memphis Regional IMF) and occur later in 

time or farther removed in distance, but occurring in the 

reasonably foreseeable future.260 Generally, these 

impacts are induced by the proposed project but are not a 

direct effect. Indirect effects can occur within the full range 

of impact types, such as changes in land use, economic 

vitality, neighborhood character, traffic congestion, air 

quality, noise, vibration, and water and natural resources. 

Examples of indirect effects can include growth-inducing 

effects and other effects related to induced changes in 

land use patterns, population density, and growth rates, 

and related effects on air and water and other natural 

systems. 

The President’s Council on Environmental Quality (CEQ) 

defines a cumulative impact as: 

...the impact on the environment which results 

from the incremental impact of the action when 

added to other past, present, and reasonably 

foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person 

undertakes such other actions. Cumulative 

impacts can result from individually minor but 

collectively significant actions taking place over a 

period of time.261 

For a cumulative impact to occur, the action must affect a 

given resource and must have the potential to interact with 

other actions with regard to that resource, either directly or 

collectively. Additionally, cumulative impacts must be 

assessed at the geographic scale at which the project may 

impact given resources and the scope of the cumulative 

impacts analysis may vary among resources.262

 

259 Effects and impacts are used synonymously in CEQ regulations. 40 C.F.R. 1508.8. 

260 40 C.F.R 1508.8b. 

261 40 C.F.R. § 1508.7. 

262 FHWA Project Development Branch, HEP-32, “Secondary and Cumulative Impact Assessment in the Highway 

Project Development Process,” April 1992.
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Cumulative impact analysis is resource specific and 

generally performed for the environmental resources 

directly impacted by a Federal action under study, such as 

a transportation project.263 The cumulative impacts 

analysis below identifies the resources to be considered in 

the analysis and, in accordance with CEQ guidance, 

assesses cumulative effects in the context of Build 

Alternative 1. Any resource which has been identified as 

potentially impacted as part of Build Alternative 1 has been 

given primary focus in the cumulative effects analysis. 

In accordance with NEPA, CEQ, TDOT, FRA, and FHWA 

requirements, cumulative impact assessments for each 

resource must consider spatial (physical) and temporal 

(duration) boundaries. For this analysis, the spatial 

boundaries for the consideration of cumulative effects are 

identified in the discussion of cumulative impacts below. 

Cumulative impacts must be considered over a specified 

time period to assess the influence of an action. 

Cumulative impacts may carry forward for decades and the 

actual time of influence attributable to a single project 

generally diminishes through time.264 The temporal 

assessment of cumulative impacts is tailored to the 

resource. For example, for local land use impacts, Fayette 

County completed its 20 year growth plan in 2003, allowing 

for land use controls and cumulative impacts analysis to 

include uses pre-dating the growth plan and through its 

implementation to 2023. CEQ NEPA regulations and 

guidance on cumulative effects do not require 

development of a catalog of specific past actions or 

quantification of these actions in a cumulative effects 

analysis, and CEQ recognizes that “because information 

about past actions may be available or obtained with 

reasonable effort does not mean that it is relevant and 

necessary to inform decision making” Guidance on the 

Consideration of Past Actions in Cumulative Effects 

Analysis. June 24, 2005.265 In accordance with CEQ 

guidance, past actions are considered collectively in 

describing the existing conditions within the spatial area 

and temporal scope of analysis for each resource. 

The cumulative impact assessment also includes 

identification of reasonably foreseeable future actions. In 

some cases, information regarding specific actions that 

have been recently commenced is available. Local and 

 

263 Questions and Answers Regarding the Consideration of Indirect and Cumulative Impacts in the NEPA Process,” 

FHWA, May 2003 http://www.environment.fhwa.dot.gov/guidebook/qaimpact.asp. 

264 FHWA, 1992.

265 CEQ, “Guidance on the Consideration of Past Actions in Cumulative Effects Analysis,” 24 Jun 2005. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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regional planning agencies and documents contain 

information relating to future land use, growth, and traffic 

projections and measures. For traffic, a combination of 

FHWA Office of Freight Management and Operations and 

specific analysis of direct effects from the traffic report was 

used to forecast cumulative traffic effects. Local and 

regional planning agencies and documents contain 

information relating to future land use, growth, and traffic 

projections and measures. Environmental effects of 

cumulative impacts are analyzed using information from 

agencies such as the EPA’s “Consideration of Cumulative 

Impacts in EPA Review of NEPA Documents”266, and 

“Habitat Evaluation: Guidance for the Review of 

Environmental Impact Assessment Documents.”267 

3.18.1 Indirect and Cumulative Impacts to Land Use 

3.18.1.1 Indirect Impacts 

While the project is located in an area already planned for 

growth and experiencing an increase in warehousing 

growth, the Memphis Regional IMF is anticipated to have 

some indirect effects on planned land uses. Local and 

regional planning bodies anticipate growth in the vicinity of 

the project area, including areas of industrial and 

residential growth. As noted in Section 1.5, the project 

location is in a portion of the Memphis area which has 

experienced a substantial increase in development since 

2002. Warehouses or distribution centers have been 

identified as a growing land use for the area. Support and 

service businesses, such as restaurants and gas stations, 

have also seen a growth. 

The indirect impacts are based on employment (“at-risk” 

jobs) from the Insight Research economic analyses.268

While these jobs could be created anywhere in the region 

and likely would not all be on Industrial Road, this 

conservative approach assumes all the predicted jobs 

would occur in businesses along Industrial Road.269 

Based on the above assumptions, the 2,105 “at risk” jobs 

can be converted to approximately 855,300 square feet of 

industrial park buildings.270 

 

266 EPA, “Consideration Of Cumulative Impacts In EPA Review of NEPA Documents, 

EPA,” May 1999.

267 EPA, “Habitat Evaluation: Guidance for the Review of Environmental Impact Assessment Documents,” January 

1993. 

268 Insight, May 2009. 

269 The Industrial Road area is currently an undeveloped field. 

270 ITE Trip Generation Manual, 8th Edition, Land Use Code “Industrial Park” used for trip generation. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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Patterns of planned land use could be changed by the 

proposed Memphis Regional IMF but many of the potential 

land use changes have been anticipated in local and 

regional land use planning and projected growth (see the 

Fayette County Growth Plan271, Town of Rossville 

Comprehensive Plan [currently being updated]272, and the 

Shelby County Growth Plan273). Marshall County does not 

have a comprehensive plan.274 The Marshall County 

Industrial Development Authority (MCIDA) is supervising 

the development of commercial and industrial areas within 

Marshall County, Mississippi.275 In particular, the 

Chickasaw Trail Management Committee is focused on the 

development in the Chickasaw Trails Industrial Park area. 

The property within this industrial/commercial zoned area 

has specific covenants to control land use and 

development.276 

Local and regional planning contemplates industrial, 

commercial, and residential growth and their impacts on air 

and water and other natural systems, including 

ecosystems. Thus, although the majority of land uses in 

Fayette and Marshall Counties are currently rural in nature, 

growth of the type that may be influenced by the Memphis 

Regional IMF is included in regional planning and 

accommodated in local land use and zoning.

The Fayette County Growth Plan was finalized in 2003 and 

provides a 20 year plan for projection of growth in the 

vicinity of the proposed Memphis Regional IMF as well as 

throughout Fayette County. The growth plan encourages 

compact and contiguous high density development and 

promotion of economic health and employment 

opportunities277, such as those land uses that would be 

directly and indirectly induced by the Memphis Regional 

IMF. Undeveloped, land bordering the project site includes 

medium and high density residential zoning (Section 3.1, 

Figure 3-2). The land north of SR-57 is zoned for business 

and land south of the site is general industrial. 

Accordingly, the Memphis Regional IMF development and 

its indirect impacts are consistent with the Fayette County 

Growth Plan and area zoning and planning. 

 

271 Terry, Bill, Fayette County Growth Plan: A Report to the Administrative Law Judge Panel, June 2009. 

272 Personal Communication with Town of Rossville Planning and Zoning, December 29, 2009. 

273 Memphis and Shelby County Division of Planning and Development, “Recommendations for Planned Growth and 

Rural Areas, Shelby County Growth Plan,” 13 Nov 2000. 

274 Personal Communication with Marshall County Planning Commission and Zoning, December 29, 2009. 

275 http://www.marshallcoms.com/. 

276 “Covenants of Chickasaw Trail Industrial Park”, http://www.marshallcoms.com/chickasaw-trail-industrial-parkmississippi.html. 

277 Terry, Bill, Fayette County Growth Plan: A Report to the Administrative Law Judge Panel, June 2009. 
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The type of industrial development induced by IMFs is 

typically light industrial, primarily warehouse distribution 

and manufacturing. 

Within the industrial zoning area, the current growth plans 

for the area authorize land uses including manufacturing, 

industrial development, and other business related uses. 

Fayette County’s industrial zoning regulations278 permit a 

range of uses including warehousing and manufacturing 

activities. The Town of Rossville’s comprehensive plan 

and zoning ordinances are being updated.279 Under the 

Zoning Ordinances of the City of Piperton, Tennessee has 

designated light manufacturing districts to allow a range of 

wholesale and light industrial establishments and to 

promote economic development.280 Shelby County, 

Tennessee’s light industrial zoning district is intended to 

provide areas in which the principle uses permitted are 

manufacturing, wholesales, and warehousing.281 

In April 2010, Marshall County changed the zoning of the 

property along Industrial Road and directly across US Hwy 

72 from Industrial Road from A-R (Agricultural-Residential) 

and R-E (Residential-Estate) to C-2 (Highway Commercial 

District) and I-1 (Light Industrial District).282 Marshall 

County, Mississippi, zoning regulations283 allow in its I-1 

Light Industrial District uses such as truck terminals, 

warehousing and distribution, assembly plants, beverage 

bottling and distribution and food packaging. C-2 is 

Highway Commercial District, which provides for retail and 

service outlets serving the needs of nearby residential 

areas and through highway traffic. 

The Memphis Regional IMF may indirectly affect the rate of 

growth of the area by bringing estimated direct and indirect 

economic benefits of $2.7 billion to the region by 2020, and 

creating or benefiting an estimated 6,186 new or benefited 

jobs in the same time period.284 Jobs created by the 

Memphis Regional IMF, both direct and indirect 

employment, would be expected to result in increased 

residential development and service businesses to support 

the increased population consistent with local and regional 

planning and growth projections. 

 

278 Personnel Communication with Fayette County Planning and Development Office, December 23, 2009. 

279 Personal Communication with Town of Rossville Planning and Zoning, December 29, 2009. 

280 City of Piperton, Zoning Ordinances, Article 7: Provisions Governing Manufacturing Districts. 

281 Shelby County, Code of Shelby County Tennessee, Appendix A: Zoning, Section 24 Industrial Districts. 

282 Personal Communication with Marshall County Zoning Office, April 2009. [Approved meeting minutes should be 

available to the public on May 13, 2010.] 

283 Marshall County Zoning Regulations, Section 10. 

284 Insight, May 2009. 
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Indirect impacts on land use would be minimized because 

any impact on land use would be consistent with land uses 

already planned for the project area and located within 

areas zoned or planned for the type of development. The 

presence of the Memphis Regional IMF is not expected to 

have a negative impact on planned growth, development, 

or land use and zoning implementation. Any potential 

changes in land use or development patterns can be 

addressed through changes to zoning and land use plans 

and provisions. 

3.18.1.2 Cumulative Impacts

Cumulative impacts associated with the proposed project 

would include the incremental impacts of the proposed 

Memphis Regional IMF when added to past, present, and 

reasonably foreseeable future land use changes within the 

areas potentially affected by the project. The direct 

impacts of the project on land use are described in Section 

3.1.2. Prior and existing land uses and future land use 

planning projections are discussed in Section 3.1.1. 

As noted in Section 3.1.2, with respect to the project site, 

the project is located with the Rossville UGB and is zoned 

for industrial use. The project site was formerly a horse 

and cattle ranch, and previous land uses in the project 

vicinity included pasture, hay, field, and forested areas. 

The Fayette County Growth Plan contemplates 

development consistent with direct and indirect land uses 

associated with the Memphis Regional IMF. Section 

3.18.1.1 above identifies indirect development, such as 

light industrial and residential development, which may 

occur in those areas in the vicinity of the proposed 

Memphis Regional IMF in suitable and properly designated 

locations for such development. An impact that may 

potentially be associated with the development in this area 

on air and water and other natural systems and resources 

is discussed in each resource discussion in subsection 

3.18.12 and 3.18.6 below. 

The Town of Rossville prepared a comprehensive plan in 

1999 and a summary report on its UGB designation.285 It 

projected a significant increase in population and the need 

for a large increase in the UGB for development. The types 

of direct and indirect development associated with the 

Memphis Regional IMF would be consistent with the 1999 

comprehensive plan. The comprehensive plan is currently 

 

285 Terry, Bill, Fayette County Growth Plan: A Report to the Administrative Law Judge Panel, June 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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being updated. The Town of Rossville is considering the 

Memphis Regional IMF as it updates the plan. 

Due to the anticipated indirect economic impacts relating to 

the Memphis Regional IMF, incremental impacts to 

industrial and residential development are likely as the 

area accommodates job growth and indirect economic 

development. The future industrial development would 

most likely be located within existing or planned areas in 

the three counties (Fayette and Shelby Counties, 

Tennessee, and Marshall County, Mississippi) that would 

most likely experience the induced development related to 

the Memphis Regional IMF. 

The types of development that normally follow the 

intermodal facilities are warehouses and distribution 

centers. Intermodal facilities do not normally attract heavy 

manufacturing or industries that use hazardous materials. 

An example of the development around an intermodal 

facility is Virginia Inland Port (VIP) in Front Royal, Virginia 

(Figure 3-30). 

Figure 3-30: Development in Front Royal VA 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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VIP is a small IMF of approximately 60 acres. Since VIP 

opened on March 1989, companies locating near VIP have 

invested over $600 million to create over 6 million square 

feet of buildings employing over 7,000 workers. These 

companies include: 

AB&C Group 

AmeriCold Logistics 

Blue Ridge (HBH) 

Prestain 

Butter-Krust Baking 

East Coast Brokers 

Family Dollar 

Ferguson Enterprises 

Ford Motor Co. 

General Parts Inc. 

Home Depot 

HP Hood Inc. 

Jouan / Precision 

Scientific 

Kohl 

Pen Tab 

Rite Aid Corp. 

Rubbermaid 

Spahr Metric Inc 

SYSCO Corp. 

Toray Plastics 

Trex 

Walden Foods 

Winchester Cold 

Storage 

World Wide Automotive 

The new jobs created by the facility, including both primary 

and secondary jobs, would likely result in an increased 

demand for housing. This housing demand could lead to 

additional conversion of undeveloped land for residential 

use and associated small businesses that are typical of 

suburban settings. This indirect growth in housing demand 

falls within the existing growth projections (population, 

housing and employment) for the region, and would be 

aligned with current planning efforts for the region to 

minimize the potential for incompatible land uses.286

However, this indirect growth associated with secondary 

jobs is not anticipated to be any greater than the impacts 

described in the Land Use Section 3.1. 

Any development resulting from residential housing 

demand would be expected to be compliant with local 

zoning and comprehensive planning efforts, which would 

minimize the potential for incompatible land uses. 

Development in Fayette County is subject to plans 

developed by the Fayette County Planning and 

Development Office, including the county’s Regional 

Subdivision Regulations.287 In Shelby County, residential 

development is subject to policies and strategies 

developed by the Department of Planning and 

Development.288 Marshall County, Mississippi is largely 

 

286 Terry, Bill, June 2009; Shelby County; Memphis and Shelby County Division of Planning and Development, 

November 2000 (reprinted with updated maps); City of Piperton, Urban Growth Boundary Report, May 2001. 

287 Fayette County, Regional Subdivision Regulations, January 2008.

288 Shelby County Department of Planning and Development, http://www.dpdgov.com. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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undeveloped and does not have specific residential 

development planning, but as noted below addresses 

economic development land use through promotion of 

special parks such as the Chickasaw Trail Industrial Park 

(an independent development). 

Secondary growth associated with additional industries 

that may avail themselves of the services of the Memphis 

Regional IMF would also comply with local zoning and land 

use requirements or other land use planning measures 

and therefore, this secondary growth would not be 

expected to have negative land use impacts. Land use 

planning and zoning measures differ amongst the three 

counties. Development closer to the project site in Fayette 

County would be subject to the growth plan and most likely 

within the Rossville UGB zoned for industrial use. 

In Mississippi, before the Memphis Regional IMF was 

proposed, the 2,600-acre, Chickasaw Trail Industrial Park 

located southwest of the intersection of Cayce Road and 

US Hwy 72 was rezoned from agricultural land use to 

industrial use.289 At the intersection of Wingo Road and 

Mt. Carmel Road, a 700,000 square foot distribution center 

(Excel) was constructed in January 2006.290 Within the 

Industrial Park, another venture broke ground in 2009 and 

a development company bought a large tract for future 

projects. 

The increased industrial, commercial and residential land 

development contemplated by regional growth and 

planning entities is expected to result in conversion of 

agricultural land to other uses. Fayette County contains an 

estimated 227,434 acres used for agricultural purposes 

(approximately 50% of the county) and Marshall County 

contains an estimated 364,175 acres used for agricultural 

purposes (approximately 82% of the county).291 As noted 

in the assessment of direct impacts, less than 0.2% of 

agricultural land in Fayette County would be affected by 

the project. According to NRCS data, agricultural land use 

has been declining in Fayette and Marshall Counties over 

the past decade. This is due to growth and development 

patterns shifting from an agricultural-based economy to a 

mixed use of residential, commercial, and agricultural 

uses. In terms of cumulative impacts, the project, including 

the 2.0 mile long Industrial Road under construction, would 

 

289 Personal Communication with Marshall County Planning Commission and Zoning, October 2009. 

290 Marshall County Industrial Development Authority, http://www.marshallcoms.com/Chickasaw_Trail/chickasaw.html.

291 Personal Communication with Fayette County Cooperative Extension Service and Marshall County Cooperative 

Extension Service, October 2009. 
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affect less than 0.2% of the agricultural acreage in Fayette 

County. 

The 2003 designation of the project area as part of 

Rossville’s UGB indicates that the conversion of 

agricultural land uses to other uses is expected to 

continue. Marshall County does not have a growth plan, 

though Marshall County Industrial Development Authority 

(MCIDA) is supervising the development of commercial 

and industrial areas within Marshall County, Mississippi. In 

particular, the Chickasaw Trail Industrial Park area has 

designated commercial and industrial. This area includes 

the property along Industrial Road in Mississippi and where 

Industrial Road would connect with US Hwy 72. 

Due to the existence of planning processes, local zoning 

regulations, and other land use controls, the large amount 

of agricultural and urban lands in the project vicinity, the 

incremental effect on land use of past, present and future 

actions when combined with the Memphis Regional IMF is 

not expected to be significant. Any cumulative impacts of 

the proposed Memphis Regional IMF that could be 

collectively significant over time would be limited by the 

land use control and designated industrial park and 

residential areas in the project vicinity. The presence of 

the Memphis Regional IMF is not expected to have a 

negative impact on the continued implementation on land 

use and planning in the project vicinity and the County can 

address potential changes in these anticipated 

development patterns via future updates to county growth 

plans, zoning, or special districts and areas. 

3.18.2 Indirect and Cumulative Impacts to Transportation 

3.18.2.1 Indirect Impacts 

Growth due to the economic benefits of the Memphis 

Regional IMF is likely to result in minor increases in traffic 

volume in those locations in the region where secondary 

industrial and residential development takes place. As 

explained in Section 3.18.1.1, the anticipated secondary 

industrial and residential development is consistent with 

land use and planning in the region, and accordingly any 

indirect impacts on traffic would be addressed within the 

region’s larger transportation planning and needs. 

The proposed Memphis Regional IMF would include a 

SR-57 overpass over the lead tracks to prevent IMF train 

impacts on that roadway. Highway traffic on SR-57 

would be maintained during the construction of the 

overpass by means of an adjacent temporary bypass. 

The bypass would be designed and constructed using 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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TDOT Standards.292 The bypass would include a 

temporary at-grade track crossing, which would be 

traversed by Memphis Regional IMF construction trains 

(an average of less than one train per day). The SR-57 

overpass construction is planned to be performed as 

expeditiously as possible to minimize any indirect 

impacts on traffic. Therefore, traffic impacts along SR57 would be insignificant. 

Existing at-grade roads crossing along the NSR 

mainline, experience brief periods during which vehicular 

traffic must yield to trains. Following its full build-out and 

operation, the proposed Memphis Regional IMF would 

add a projected four eastbound trains terminating at the 

facility and four westbound trains originating at the 

facility per day. (It should be noted that other NSR rail 

traffic not related to the Memphis Regional IMF would 

also impact train volumes.) The proposed Memphis 

Regional IMF is being designed to accommodate trains 

8000 feet or longer in length, which would minimize the 

number of trains necessary to accommodate IMF’s 

projected traffic volumes, thereby also minimizing 

potential rail-automobile crossing conflicts. 

Another indirect transportation effect of the Memphis 

Regional IMF would include substantial mitigation of 

roadway congestion due to fewer long-distance trucks 

utilizing the highways between the Memphis region and 

the Northeast U.S. Figure 3-31 shows sources for 

congestions.293 Associated with congestion mitigation 

would be improvements in safety and fuel efficiency.294

The Mississippi Strategic Highway Safety Plan295 outlines 

the State of Mississippi’s mission, vision, and goal for 

prioritizing and coordinating safety initiatives to allow 

available funding to produce the greatest results in 

reducing traffic injuries and fatalities. Mississippi would 

identify areas and initiatives with the greatest potential to 

substantially reduce traffic fatalities through such 

measures as: reducing impaired driving, increasing seat 

belt usage, preventing or reducing the severity of lane 

departure crashes, reducing the over-involvement of young 

drivers, and curbing aggressive driving. 

 

292 TDOT, Work Zone Safety & Mobility Manual, November 29, 2007. TDOT, Transportation Management Plan 

Workbook, http://www.tdot.state.tn.us/Chief_Engineer/assistant_engineer_design/design/TMPWorkbook.dot. 

293 NSR, “Form: 8-K:, 12 Jun 2007, http://google.brand.edgaronline.com/EFX_dll/EDGARpro.dll?FetchFilingHTML1?SessionID=Ya3uWJ3XXzYY1uh&ID=5241016. 

294 Cambridge Systematicsx, Inc. 2005. Traffic Congestion and Reliability: for the FHWA, September 1, 2005. 

295 MDOT, Mississippi Strategic Highway Safety Plan, January 2007. 
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Figure 3-31: The Sources of Congestion 

One method to calculate the volume of vehicular traffic 

cumulatively connected to the Memphis Regional IMF is to 

use the employment numbers from the Insight Research 

economic analyses.296 The employment impact included 

both direct and indirect employment for both construction 

and operating phases of the Memphis Regional IMF and 

associated industrial area expansion. Direct intermodal 

employment refers to persons involved with the operation 

of the Memphis Regional IMF, either on-site, or, as an 

example, the truck drivers delivering and picking up the 

containers and trailers in the Memphis region. Indirect 

employment refers to jobs generated by the purchase of 

goods and services by the facility and its direct employees. 

Jobs at the area businesses that would utilize the 

transportation services of the Memphis Regional IMF are 

another employment category, with both the direct and 

indirect components. Some of the area customer jobs 

(called “at-risk”) would not exist without the Memphis 

Regional IMF, while others (called “benefited”) would exist 

without the Memphis Regional IMF, but their employers still 

benefit from its services. The box in the right margin 

provides additional details of these categories. These 

impacts are predicted to occur within a 50-mile radius of 

the IMF. 

 

296 Insight, May 2009. 
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Table 3-19: 2020 Employment Impacts of Memphis Regional IMF 

Employment Total 

Proposed Intermodal - Direct Impact 926 

At Risk (Potential Intermodal Dependent Industrial Development) 1,565 

Potential Benefited (Potential Impacts by Intermodal Availability) 3,695 

Total (Exclusive of Construction) 6,186 

To better define the potential traffic impacts from the 

creation of the Memphis Regional IMF, additional traffic 

analyses were completed.297 The predicted traffic impacts 

based on the employment for the “at risk” industrial area 

expansions were included in the traffic analyses. Applying 

the CEQ definitions for direct, indirect and cumulative 

impacts, the analyses for 2032 included the assumptions 

at MDOT’s direction that: US Hwy 72 would be a four-lane 

divided highway, a rural principle arterial, with a design 

speed of 70 mph. The direct traffic impacts were analyzed 

in Section 3.3.3. 

The indirect impacts based on employment (“at-risk” jobs) 

were extrapolated using the 1,565 predicted jobs from 

2020 to 2105 predicted jobs for 2032. While these jobs 

could be created anywhere in the region and likely would 

not all be on Industrial Road, this conservative approach 

assumes all the predicted jobs would occur in businesses 

along Industrial Road.298 

Based on the above assumptions, the traffic projected for 

Industrial Road consisted of 1,974 trucks and 334 

passenger vehicles per day of direct impact and 5,953 vpd 

of indirect impact. 

Based on the ITE Trip Generation Manual, 8th Edition, the 

trips generated by 2105 industrial employees are shown in 

Table 3-20. The indirect traffic mixture was assumed to be 

30% trucks and 70% passenger cars based on the 

assumption that part of the traffic would be individuals 

driving to work for these additional jobs in their personal 

vehicles. 

 

297 AECOM, “Analysis of Projected Traffic and Impacts in the Vicinity of the Intersection of US Hwy 72 and Industrial 

Road”, May 10, 2010, on file with TDOT and MDOT (Nashville, TN: AECOM) and Calculations for various scenarios using 

ITE Trip Generation Manual, 8th Edition. 

298 The Industrial Road area is currently an undeveloped field. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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Table 3-20: Indirect Trips Potentially Generated 

Daily 

Traffic 

AM Peak Hour PM Peak Hour 

Enter Exit Enter Exit 

Trucks 1,786 221 36 49 196 

Passenger Vehicles 4,167 517 84 114 457 

Total 5,953 738 120 163 653 

The review of the traffic analyses indicate that based on 

the 2032 projected direct, indirect, and 2.5% background 

growth rate traffic volumes, additional improvements would 

be required for the T intersection currently defined by the 

traffic study outlined in Section 3.3.3. As required in the 

May 2010 Industrial Road Traffic Analysis, the intersection 

of US Hwy 72 and proposed Industrial Road requires a 

signal control.299 These project-required improvements 

would be made by the private Developer in conjunction 

with the MDOT Highway Occupancy Permit (HOP)

The following measures are required to address the 

predicted direct, indirect, and background growth impacts 

of the Memphis Regional IMF on the intersection of US 72 

and Industrial Road.300 These required improvements are 

illustrated in Figure 3-36. 

 Signalize the intersection of US 72 and Industrial 

Road. 

 Design Industrial Road to provide three 

southbound lanes, two for left turning vehicles 

and one for right turning vehicles. The 

southbound left turn lanes should each provide 

storage and transition space. 

 Channelize the southbound right turning 

movement on Industrial Road at US 72. 

 Provide dual eastbound left turn lanes, each with 

storage and transition space on US 72 at 

Industrial Road. Use 16-foot wide lanes for the 

dual left turn lanes and receiving lanes to 

accommodate heavy vehicles. 

 Design the intersection of US 72 and Industrial 

Road with acceleration and deceleration lanes. 

 

299 AECOM, May 10, 2010. 

300 For the purpose of NEPA studies for the IMF, the 2.5% growth per year is included as a cumulative effect (i.e. effects 

which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable 

future actions regardless of what agency or person undertakes such other actions, including minor but collectively 

significant actions taking place over a period of time. 40 C.F.R. § 1508.7). Other cumulative effects include but are not 

limited to those related to the intermodal facility, either directly or indirectly. 
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Figure 3-32: Improvements to Four-Lane Segment of US Hwy 72 

The background traffic on US Hwy 72 was 19,808 vpd of 

total impact. Figure 3-33 represents the approximate 

28,069 vpd that US Hwy 72 is expected to carry in 2032, 

without apparent congestion. 

Figure 3-33: Projected Roadway Volumes on Four-Lane Segment of US Hwy 72 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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3.18.2.2 Cumulative Impacts 

Cumulative impacts associated with the proposed project 

would include the incremental impacts of the proposed 

Memphis Regional IMF on traffic when added to past, 

present, and reasonably foreseeable future changes in 

traffic within the areas potentially affected by the project. 

The direct impacts of the project on traffic, as well as 

existing traffic assessment in the project vicinity, are 

described in Section 3.3.3. 

a. Roadway 

Industrial Road would connect the facility to US Hwy 72 in 

Mississippi at a still two-lane section. MDOT is planning to 

widen this section of US Hwy 72 from two-lanes to fourlanes.301 Construction of US Hwy 72 from MS 302 to the 

Tennessee state line was programmed in the Mississippi 

Statewide Transportation Improvement Plan (STIP) for 

2012 on October 14, 2009.302

In addition recent Mississippi legislation, S. B. No. 3181 

amending portions of Mississippi Code of 1972, Title 65, 

Chapter 4, added “[a]ny project which would allow access 

to a national intermodal facility with a minimum capital 

investment of One Hundred Million Dollars 

($100,000,000.00) that is located within five (5) miles of the 

State of Mississippi and has direct access into an industrial 

park within the state” to the list of “High economic benefit 

projects" that political subdivisions can apply for state 

assistance to fund construction or improvement of any 

highways or highway segments.303 Political subdivisions 

can apply for state assistance to fund construction or 

improvement of any highways or highway for the primary 

purpose of encouraging a private company to engage in a 

high economic benefit project within the geographic 

boundaries of the political subdivision. The legislative goal 

of ‘encouraging’ economic benefit cannot be achieved with 

respect to the Memphis Regional IMF because the 

Memphis Regional IMF was already independently 

developed and approved for receipt of Federal TIGER 

grant funding under the American Reinvestment and 

Recovery Act prior to the enactment of the abovereferenced legislation, and other provisions in the 

legislation would not apply to the Memphis Regional IMF. 

Any improvements at the intersection of Industrial Road 

and US Hwy 72 may be subject to the new legislation 

 

301 MDOT Planning Division, “Vision 21 map,” 2002. 

http://www.gomdot.com/Divisions/IntermodalPlanning/Resources/Maps/pdf/Vision21.pdf

302 Mississippi DOT 2010-2013 STIP, US72 from FR302 to Tennessee State Line, NEED 10 4752. 

303 Mississippi SB 3181 
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should a local political subdivision seek funding and should 

the party proposing the high economic benefit project 

submit a letter of intent to the local political subdivision. 

Improvements at Industrial Road and US Hwy 72 could 

permit increased development in the Chickasaw Trail 

Industrial Park south of US Hwy 72 by allowing truck traffic 

easier access between I-269 at MS 302 and the Memphis 

Regional IMF. Such improvements could also permit the 

potential development of a private roadway network within 

the Industrial Park for heavier container/trailer loads and a 

short-line rail connecting to NSR. 

The stretch of US Hwy 72 in Tennessee, which connects to 

SR-385, is a four-lane highway. SR-385 is four-lanes from 

I-240 to SR-57. TDOT has programmed SR-385 to be 

four-lanes from SR-57 north to Interstate 40 (I-40), which 

would allow for truck traffic from I-40 to effectively bypass 

Germantown and Collierville (Figure 3-34).304 

Figure 3-34: Proposed Location of SR-385 

The improvement to SR-385 would be constructed to 

interstate standards and it would be re-designated as I-269 

 

304 TDOT, “State Route 385,” http://www.tdot.state.tn.us/sr385/. 

US Hwy 72 

SR-57 

I-40 
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once the connections are complete. I-269 would depart 

from SR-385 in Tennessee near the junction with US Hwy 

72. The proposed improvements and construction of I69/I-269 road project would allow for improved truck traffic 

flow around the Memphis area (Figure 3-35).305 

Figure 3-35: Proposed Location of Southeast Section of I-269 

Mississippi STIP lists the construction of I-269 (MS 304) 

from MS 302 to the Tennessee state line in 2011 and from 

US Hwy 78 to MS 302 in 2012 (Figure 3-36).306

Cumulative impacts to traffic in the region may result from 

past growth including the increase in some industrial 

sectors such as warehousing as described in Section 

3.1.1, growth in Fayette and Marshall Counties described 

in the land use cumulative impacts at 3.18.1.2, as well as 

future planned infrastructure improvements and policies 

and practices of Federal, State and Local transportation 

agencies. Planned roadway infrastructure improvements 

to US Hwy 72, SR-385, and I-69/269 are potential road 

improvement projects which may have cumulative effects 

on traffic. These roadway improvements are expected to 

improve traffic flow, safety and LOS. 

The construction of SR-385 is discussed in Section 2.1 and 

is expected to provide favorable transportation options for 

the local area. Section 3.3.3 summarizes the incremental 

impacts of the proposed Memphis Regional IMF on 

 

305 TDOT, System Alternative Map from Newsletter, http://www.tdot.state.tn.us/i69/segment9/newsletters/1204.pdf and 

TDOT I-69 Website, http://www.tdot.state.tn.us/I69/default.htm. 

306 Mississippi DOT 2010-2013 STIP 

NSR Mainline 

Fayette Co. 

US Hwy 72

SR-385 

SR-57 
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existing and future traffic anticipated on US Hwy 72. The 

study concludes that the four-lane configuration provides 

adequate LOS to accommodate proposed Memphis 

Regional IMF traffic and discusses that MDOT is 

programming to widen this section of US Hwy 72 from twolanes to four-lanes to accommodate even greater traffic 

volumes whether the proposed project is built or not.307 

The traffic study concludes that the capacity of US Hwy 72, 

even after the addition of future projected traffic growth 

unrelated to the Memphis Regional IMF, would be more 

than adequate to accommodate increases traffic from the 

Memphis Regional IMF. The traffic impacts on US Hwy 72 

resulting from the IMF will not be substantial. 

Figure 3-36: Proposed Location of I-269 in Mississippi 

As noted in Section 3.18.1 above, land use and growth 

planning for the region predicts economic growth in region. 

Traffic volumes would likely increase with economic 

growth. Section 3.3.3 outlines current traffic baseline and 

direct impacts from the proposed Memphis Regional IMF. 

Traffic analyses projected future traffic volumes and 

concluded that traffic on the four-lane section of US Hwy 

72 in the vicinity of the Memphis Regional IMF would 

maintain acceptable level of service. 

According to the Developer, Industrial Road is anticipated 

to open with an at-grade connection at US Hwy 72 in 2010. 

 

307 AECOM, “Memphis Intermodal Facility, Traffic Impact Study” November 2009 Revision, on file with TDOT and MDOT 

(Nashville, TN: AECOM). 
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The zoning for the 661.75 acres308 in the area was 

changed in April 2010 to commercial/industrial. The 

Developer plans for Industrial Road to serve the planned 

development on his properties (1,556 acres of land in 

Tennessee and Mississippi). The cumulative traffic impact 

from the proposed adjacent developments along Industrial 

Road could increase the traffic volumes along Industrial 

Road. The development along Industrial Road would 

develop in accordance with the current and future zoning 

regulations for Rossville, TN, and Marshall County, MS. 

This anticipated increase over the IMF only traffic could 

create congestion along the planned two-lane Industrial 

Road. Based on the growth along Industrial Road, the 

Developer would have to widen the access to continue to 

develop his adjacent property. Cumulative impact from the 

IMF and adjacent development on Industrial Road traffic is 

not anticipated to affect Mount Pleasant located 

approximately 5 miles east of Industrial Road because 

most traffic on US Hwy 72 would be going or coming from 

the west to the proposed Memphis Regional IMF. In 

addition, Mount Pleasant is located along the four-lane 

section of US Hwy 72 and any additional traffic is not 

predicted to have a significant negative impact on LOS in 

the four-lane sections of US Hwy 72. 

The Developer joined the Chickasaw Trails Industrial Park 

(light blue area shown in Figure 3-37). The cumulative 

traffic impacts from other industrial parks along US Hwy 72 

and MS 302 in Mississippi, such as the 3,000+ acre 

Chickasaw Trail Industrial Park, could create a substantial 

increase in the traffic count in this area upon full build-out. 

A fully developed Chickasaw Trail Industrial Park (Figure 

3-35)309 based on its size and light Industrial type of 

development, could generate substantial traffic. Marshall 

County could apply for state assistance to facilitate this 

development and develop highway improvements to 

accommodate the potential increases in traffic, per the 

recent Mississippi legislation. 

Currently, the Chickasaw Trail Industrial Park is built out to 

only a fraction of its designed capacity, and anticipated 

build-out would follow local economic growth and demand 

projections. 

 

308 “The Southern Reporter”, Legal Notice, March 25, 2010. 

309 Provided by Director of Marshall County Industrial Development Authority, March 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPO

Memphis Regional Intermodal Facility 3-157 6/30/2010 

Figure 3-37: Chickasaw Trails Industrial Park 
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The already proposed and programmed transportation 

infrastructure improvements along US Hwy 72, I-269, I-69, 

MS 302, MS 304, and SR-385, along with the potential for 

state funding to develop highway improvements, recently 

authorized by the Mississippi legislation should be 

adequate to handle the predicted increase in traffic 

volumes from both Industrial Road and other surrounding 

industrial developments. 

Another potential traffic impact along Industrial Road is the 

Developer’s proposed short-line rail spur parallel to 

Industrial Road to serve Developer’s properties planned for 

the Chickasaw Trail Industrial Park development. Due to 

speculative nature of this addition, it is hard to predict if the 

rail spur would be constructed, if businesses desiring this 

transportation connection would locate in the one of the 

nearby industrial parks, and if NSR would agree to its 

connection to their rail system. The Developer also has 

plans for the rail spur to connect under US Hwy 72 in 

Mississippi. Based on its location, expected low rail traffic 

volumes, and the MDOT requirement that the rail line is 

grade separated from US Hwy 72, any rail traffic on shortline track should have a minimal affect on roadway traffic. 

Cumulative traffic impacts further from the proposed 

project site are expected to be diluted by other anticipated 

growth and traffic management issues. Because growth in 

the area would likely follow the development plans and 

because transportation improvement projects are 

implemented as a matter of law and policy where growth 

occurs, long-term negative impacts to traffic and 

transportation would not be expected. At most, congestion 

due to growth would likely result in episodic reductions in 

level of service. Implementation of transportation 

improvement projects would likely alleviate these 

conditions. The Memphis and Shelby County Division of 

Planning and Development has adopted a congestion 

management system approach wherein congestion is 

assessed periodically for consideration of necessary 

infrastructure improvements or other measures.310 

As discussed in Section 3.18.1.2, the types of 

development that normally follow the intermodal facilities 

are warehouses and distribution centers that either transfer 

the containers and trailers or use the IMF to transport their 

goods. Intermodal facilities do not normally attract heavy 

manufacturing or industries that use substantial amounts of 

hazardous materials. 

 

310 Memphis Urban Area Metropolitan Planning Organization (MPO) Congestion Management System Plan (2001).
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Current traffic studies within the Memphis area, are being 

conducted or being planned by TDOT, MDOT, and the 

Memphis Urban Area MPO for the larger Memphis and I69 areas. MDOT is currently holding public meeting 

discussion alternative plans for I-69 Corridor Alternative 

Analysis (Figure 3-38).311 The Memphis MPO had multiple 

studies on-going and planned to identify goals, determine 

potential development, and allocate transportation 

investment. Current studies near the proposed Memphis 

Regional IMF include the Southern/Poplar Corridor Study 

and the Houston Levee Study. In mid-March 2010, public 

meeting and workshops would be held for Image 2035: 

Mid-South Transportation + Land Use (IMAGE 2035), a 

regional planning process.312 In accordance with NEPA, 

as these projects move forward any cumulative effect of 

the Memphis Regional IMF would be considered in future 

traffic studies and assessments. 

Figure 3-38: I-69 Corridor Alternative Analysis 

As defined in regulations implementing NEPA, cumulative 

impacts associated with the proposed project would 

include the incremental impacts of the proposed Memphis 

Regional on freight transportation resources when added 

to past, present, and reasonably foreseeable future 

changes and impacts on those resources within the areas 

potentially affected by the project.313 

 

311 http://www.i69aa.com 

312 http://www/Memphismpo.org. 

313 40 C.F.R. 1508.7 (2009). 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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b. Rail 

The genesis of the current freight rail system was a part of 

early rail development in the nineteenth century. 

Substantial development of rail lines took place in the 1850 

to 1890 time frame, with development of major east-west 

corridors. Many states built state-owned lines, and federal 

land grants were established in recognition of the 

importance of rail transportation to the United States. This 

early rail growth spurred economic growth in farming and 

industry, with indirect benefits to settlement and 

development in the nation.314 

As a recognized important national interest, State and 

Federal government have promoted freight transportation 

by rail through legislative and policy initiatives from the 

early years of rail transportation in recognition of the early 

importance of rail in national economic growth. The 

Department of Transportation, the former Interstate 

Commerce Commission (ICC) (prior to its sunset in 1996), 

and the Surface Transportation Board (STB) (following 

1995), have developed comprehensive programs and 

policies regarding intermodal freight transportation. 

Intermodal was first identified as a separate category of 

freight transportation in 1955. Encouragement of 

intermodal transportation was a central policy of the ICC, 

which determined that intermodal transportation presented 

numerous national benefits including energy conservation, 

reduced congestion, increased efficiency and speed, and 

reduced freight damage.315 The STB and DOT have 

continued national policy promoting intermodal in 

accordance with Congressional enactments. 

In 1991, Congress enacted the Intermodal Surface 

Transportation Efficiency Act of 1991 (ISTEA). The policy 

of the 1991 ISTEA was to provide for economically efficient 

and environmentally sound transportation policy, providing 

the foundation for the Nation to compete in the global 

economy and move people and goods in an energy 

efficient manner.316 In its 1994 report to Congress on 

intermodal transportation pursuant to ISTEA, the National 

Commission on Intermodal Transportation recommended 

development of a National Intermodal Transportation 

System including the nation’s rail, highway, and marine 

transportation resources. The National Intermodal 

Transportation System was planned to foster development 

of freight transportation investment, provide federal funding 

 

314 Tindall, “America, A Narrative History”’ at 437-41 (1st Ed. 1984); DePew, One Hundred Years of American Commerce 

(1895). 

315 Zirbel Transport, Inc., Ext.—Containers, 125 M.C.C. 663 (1976). 

316 Pub.L.No. 102-240, Sec. 2. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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incentives for projects of national or regional significance, 

and more flexible and expanded eligibility of State and 

Federal funds for intermodal projects of public benefit.317 

The TEA-21, enacted in 1998, reaffirmed the national 

commitment to intermodal transportation and the policy 

toward enhancing the integration and connectivity of the 

transportation system initiated in the 1991 ISTEA 

legislation.318 In 2003, Congress enacted the National 

Intermodal Transportation System Policy, citing the 

promise of intermodal transportation systems to “reduce 

energy consumption and air pollution while promoting 

economic development and supporting the United States' 

preeminent position in international commerce.”319 

Recently, FHWA and the United States Environmental 

Protection Agency have collaborated on intermodal policy 

to help address Clean Air Act goals. The Congestions 

Mitigation and Air Quality (CMAQ) Improvement Program 

promotes intermodal transportation projects that reduce 

mobile source emissions in areas that are designated by 

EPA as nonattainment with national ambient air quality 

standards. The CMAQ program identifies some of the 

benefits are enhanced mobility by shifting traffic from 

congested highways to rail or marine networks, providing 

environmental benefits by employing the cleanest possible 

technologies that improve air quality.320 

Today, the national intermodal system is a part of the 

nation’s transportation infrastructure, supported by public 

and private investment and spanning throughout the 

United States and providing connectivity abroad. DOT, 

through the FRA, FHWA, and DOT and in conjunction with 

the STB, support the development and policy regarding 

intermodal transportation. The intermodal system operates 

in each state and the District of Columbia, and is 

connected with the National Highway System at a number 

of points throughout the United States.321 Within the over 

160,000 mile National Highway System, FHWA has 

identified over 1,400 passenger and freight intermodal 

connectors.322 Of the over 1,400 passenger and freight 

 

317 “Toward a National Intermodal Transportation System: Final Report,” National Commission on Intermodal 

Transportation, at 3 (Sept. 1994). 

318 Pub. L. No. 105-178, 49 U.S.C. § 302(e). 

319 49 U.S.C. § 5501. 

320 http://www.fhwa.dot.gov/environment/cmaqpgs/intermodal/index.htm (FHWA-HEP-05-021HEP-10-05(4M)E (Oct. 

2005). 

321 http://www.fhwa.dot.gov/planning/nhs/intermodalconnectors/index.html. 

322 FHWA, Freight Management and Operations, NHS Connectors, at Chapter II (undated), 

http://ops.fhwa.dot.gov/freight/freight_analysis/nhs_connectors/role_nhs_conn/role_sys_conn_2.htm. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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intermodal connectors, FHWA has identified 211 truck/rail 

terminal connectors. 

FRA, FHWA, the American Association of State Highway 

and Transportation Officials, the AAR, and other 

organizations project substantial growth in the use of rail 

freight transportation. The Bureau of Transportation 

Statistics estimated growth in domestic rail freight of over 

25% per year from 1996 to 2005, and anticipates growth 

for rail freight including intermodal to continue. As a 

percentage of total freight transportation, the Bureau 

estimated rail freight grew from 25% to over 38% of total 

freight ton-miles from 1996 to 2005.323 Freight 

transportation tonnage for rail is projected to increase by 

44% by the year 2020.324 

The Memphis Regional IMF is proposed to be a part of 

NSR Crescent Corridor, which has as its core existing 

intermodal mainlines with double stack capacity operating 

from Tennessee and Alabama to Pennsylvania and New 

Jersey. The Crescent Corridor has a number of existing 

and proposed intermodal facilities. With the projected 

growth in rail freight transportation, it is foreseeable that 

improvements to intermodal lines and the national 

transportation system would occur. These improvements 

are likely to include new intermodal connection points, rail 

line improvements, and potentially new terminals and 

intermodal facilities. NSR is in the planning stage for 

improvements for the Crescent Corridor which would 

include new or expanded intermodal facilities in the 

Birmingham, Alabama, region; Greencastle, Pennsylvania, 

and Harrisburg, Pennsylvania. Each of these 

improvements serves independent local or regional 

transportation demand needs, but would also have 

cumulative effects on the intermodal system. These 

cumulative effects would include increase usage of the 

main line rail system for intermodal shipment, increased 

efficiency of transportation, and reduced use of highways 

for long-haul trucking between intermodal points. These 

cumulative effects would be in addition to the direct effects 

of the Memphis Regional IMF on rail line usage, long-haul 

trucking, and transportation efficiency. It is difficult to 

predict cumulative effects of reasonable foreseeable 

actions, but it is anticipated that effects would include 

overall reduction in fuel consumption, reductions in 

greenhouse gas emissions, and safety and highway 

benefits. It would also be an expected increase in rail 

traffic. 

 

323 Bureau of Transportation Statistics, Special Report: A Decade of Growth in Domestic Freight (July 2007). 

324 American Association of State Highway and Transportation Officials, Freight-Rail Bottom Line Report (2009). 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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With respect to highway congestion, FHWA studies 

indicate that daily long-haul traffic is anticipated to increase 

significantly along the I-40 corridor.325 Figure 3-39 

illustrated the projected 2020 congestion along Tennessee 

Interstates along with NSR’s mainline tracks, where the 

long-haul cargo could be shifted.326 

The Memphis Regional IMF would help facilitate moving 

freight long distances by rail rather than by highway, thus 

reducing long-haul trucks. As noted in Section 3, trains, 

each of which is capable of carrying the equivalent of 280 

truck-loads of freight 327, reduce long-haul truck traffic on 

congested highways, and result in improvements to safety, 

energy usage, and air quality.328

Figure 3-39: Projected 2020 Tennessee Interstate Highway Congestion 

3.18.3 Indirect and Cumulative Impacts to Social and 

Community Resources 

3.18.3.1 Indirect Impacts 

The Memphis Regional IMF is anticipated to create or 

benefit an estimated 6,186 direct and indirect jobs and 

bring direct and indirect economic benefits estimated at 

$2.7 billion to the region by 2020.329 As noted in 3.18.1.1, 

the potential for jobs at the proposed Memphis Regional 

IMF could help to encourage more people to move to the 

area. 

 

325 FHWA, Office of Freight Management and Operations, Freight Analysis Framework. 

http://ops.fhwa.dot.gov/freight/freight_analysis/faf/index.htm. 

326 FHWA, Office of Freight Management and Operations, 

http://ops.fhwa.dot.gov/freight/freight_analysis/congestion/index.htm. 

327 Association of American Railroads (AAR), Freight Rail Works 280 Fact Sheet, 2009, 

http://www.freightrailworks.org/280.html. 

328 FHWA, http://www.fhwa.dot.gov/congestion/, http://www.fhwa.dot.gov/environment/cmaqpgs/index.htm;

329 Insight, May 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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The increase in jobs would likely increase residential 

population in the vicinity of the project, most likely within 

Fayette and Shelby Counties, Tennessee, and Marshall 

County, Mississippi. The types of indirect impacts likely 

from increased residents are potential increases in schoolaged children and the associated demand on school 

infrastructure, increased need for other community and 

social services such as police, fire, churches, and other 

community organizations. As noted below in Section 

3.18.3.2 and in the Fayette County Growth Plan, growth in 

the county has already been anticipated prior to the 

proposal for the Memphis Regional IMF, and plans are in 

place to accommodate growth through planning provisions 

and policies. Growth would be controlled through land use 

and other planning mechanisms. Accordingly, the indirect 

impacts are expected to be insignificant. 

3.18.3.2 Cumulative Impacts

Cumulative impacts associated with the proposed project

would include the incremental impacts of the proposed 

Memphis Regional IMF on social and community 

resources when added to past, present, and reasonably 

foreseeable future changes in impact on those resources 

within the areas potentially affected by the project. 

Cumulative impacts of growth in the area could potentially 

strain the capacities of local community resources, such as 

schools, community and social services such as police, 

fire, churches, and other community organizations, and 

could affect local government budgets. However, the 

impact is expected to be minimal due to planning policies 

and measures as well as the demographics of the region. 

Fayette County has been planning for growth. Fayette 

County’s population grew by 11% in the 1970s, 1% in the 

1980s, and 19.2% in the 1990s.330 From 2000 to 2008, 

Fayette County’s population grew 32% to approximately 

38,000.331 Fayette County’s current population of 

approximately 38,000 is expected to increase to over 

54,000 by 2020.332 

While growth in Fayette County has been significant 

spurring land use planning activities, the total population in 

Fayette County is eclipsed by neighboring Shelby County. 

Shelby County’s residential population is expected to 

remain relatively stable or slightly decrease from its 

 

330 Regional Economic Development Center, The University of Memphis, “Population Projections for Piperton, 

Tennessee,” September 1999.

331 U.S. Census Bureau, “State and County QuickFacts Fayette County, Tennessee,” 17 Nov 2009. 

332 TACIR and The University of Tennessee Center for Business and Economic Research, “Population Projections for 

the State of Tennessee, 2010-2030,” June 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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existing 910,000 to approximately 875,000 residents.333

East Shelby County and Collierville, which are in the 

closest proximity to the proposed Memphis Regional IMF, 

have been experiencing a high rate of growth. From 1990 

to 2000, Collierville experienced a 121% population 

increase334 compared to Tennessee’s increase of 16.7% 

for the same time period. The latest Special Census count 

for Collierville certified by the state in 2008 showed a 

population increase of 39% from 2000.335 Collierville’s 

Land Use Plan, I-269 Small Area Plan, and the Downtown 

Area Plan (under development) indicate opportunities for 

growth within Collierville and its UGB. Some negative 

cumulative impacts could occur due to the additional 

growth related to the Memphis Regional IMF. 

With the growth planning in place in Fayette County and its 

relatively low density and large amount of undeveloped 

land, the proposed project’s relative effect on community 

and social resources would represent a relatively small 

percentage of overall growth and resulting cumulative 

impacts. In Shelby County, with its much larger and 

relatively high density population projections, any 

additional cumulative impacts to social and community 

resources would be minor and readily accommodated by 

existing or planned resources. 

3.18.4 Indirect and Cumulative Impacts to Economic 

Resources 

3.18.4.1 Indirect Impacts 

The Memphis Regional IMF would have both short- and

long-term indirect beneficial impacts. As noted in Section 

1.2, the Memphis Regional IMF is anticipated to contribute 

to an estimated economic impact of $2.7 billion in the 

region by 2020.336 The Memphis Regional IMF is 

anticipated to create or benefit an estimated 6,186 direct 

and indirect jobs by 2020.337

Indirect short-term beneficial impacts would be realized in 

the additional jobs created both on- and off-site during 

construction and site development. Indirect employment 

would result in the form of jobs associated with the 

provision of supportive goods, supplies, and services 

necessary for the construction phase of the project. This 

creation of indirect employment would result in additional 

 

333 TACIR and UT, 2009. 

334 Town of Collierville, Comment Response Letter to TDOT on Draft EA, March 5, 2010. 

335 Town of Collierville, March 5, 2010 Letter. 

336 Insight, 2009.

337 Insight, 2009. 
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indirect personal income for the purchase of goods and 

services within the region. 

Indirect long-term economic impacts would result from the 

operations of the Memphis Regional IMF and associated 

development. These impacts would be the indirect 

employment and personal income created because of 

additional business generated from the operations of the 

Memphis Regional IMF. Local and regional retail and 

service outlets would realize increased business volume 

and personal income. In addition, local and regional 

vendors of goods and supplies for the businesses within 

the project area would benefit from the proposed action. 

Other indirect benefits would result from the potential 

expansion of existing businesses and the development of 

new businesses that would utilize the freight transportation 

and other services offered through the IMF. Examples 

could be the new businesses locating on property along 

Industrial Road or in the Chickasaw Trail Industrial Park 

(an independent development) in Mississippi or other 

industrial sites available in Holly Springs, Byhalia and Potts 

Camp, Mississippi. In addition, indirect benefits would 

result from service/support businesses, such as gas 

stations and restaurants, which could locate in the areas 

zoned commercial along US Hwy 72 or in nearby towns. 

However, Mount Pleasant, Mississippi, located 

approximately 5 miles east of the proposed Memphis 

Regional IMF is anticipated to receive little indirect benefits 

or negative impacts from the facility as most vehicle traffic 

using US Hwy 72 would not be heading to or coming from 

the direction of Mount Pleasant.338

A Workforce Investment Network (WIN) job center will be 

opening in Holly Springs.339 With the proposed Memphis 

Regional IMF coming to the area, the job center would help 

prepare and train the local unemployed workforce for job 

opportunities. As of January 2009, Marshall County had 

an unemployment rate of 11.2%.340 A consortium of the 

Mississippi Department of Employment Security (MDES), 

Marshall and Benton Counties, Holly Springs, Byhalia, 

Potts Camp, Ashland, and Snow Lake will fund the job 

center. 

Over the last 10 years (without the proposed Memphis 

Regional IMF), NSR has helped attract $63 million in 

investment in new or expanded industries in Mississippi, 

creating an estimated 460 jobs. In Mississippi, NSR has 

 

338 Personal communication, Executive Director of Marshall County Industrial Development Authority, March 2010. 

339 Personal Communication, Holly Springs Chamber of Commerce, March 2010. The South Reporter, March 25, 2010. 

340 MDES, Labor Market Data Publications, January 2010. 
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approximately 210 route miles with 190 employees earning 

a $13 million annual payroll and $82 million in annual 

purchases and payments.341 Over the last 10 years 

(without the proposed Memphis Regional IMF), NSR 

helped attract $163 million in investment in new or 

expanded industries in Tennessee, creating an estimated 

1,220 jobs. In Tennessee, NSR has approximately 850 

route miles with 1,440 employees earning $97 million 

annual payroll and $68 million in annual purchases and 

payments.342 

As noted in Section 3.6.2, increased economic 

development is likely to result in conversion of some 

existing agricultural lands. However, large areas of total 

available agricultural lands are currently available within 

Fayette and Marshall Counties, such that the net impact 

from indirect economic development relating to the 

Memphis Regional IMF is expected to be minimal. 

3.18.4.2 Cumulative Impacts 

The Memphis Regional IMF would create improved and

expanded transportation services in the Memphis region by 

providing for more economically efficient movement of 

goods by a combination of truck and rail. Currently, the 

region lacks capacity to effectively transport the projected 

volumes of freight that would move through the area. 

Based on a regional economic benefits study, the freight 

transportation demand in the Memphis area with the 

Memphis Regional IMF could contribute to a cumulative 

economic impact of $2.7 billion by 2020, and to employment 

growth of 6,186 new and benefited jobs in the same period.343

The Memphis Regional IMF would result in benefits in the 

form of additional jobs, personal income, transportation 

costs savings, and other monetary returns associated with 

manufacturing and distribution activities. The demand for 

long-haul truck drivers is expected to increase. The use of 

IMF would flatten the rate of increase demand by diverting 

loads from long-haul trucks to IMF trains and short-haul 

truckers. The projected 429 jobs directly associated with 

the operation of the Memphis Regional IMF include 290 

“full time equivalent” drayage344 truck driver jobs. The 

direct jobs would result in 336 indirect short-haul driver 

jobs (these jobs are part of the 497 indirect jobs as shown 

in Figure 1-3). 

 

341 http://www.thefutureneedsus.com/states/mississippi.html 

342 http://www.thefutureneedsus.com/states/tennessee.html 

343 Insight Research Corp, May 27, 2009 

344 Drayage is a term used by the industry to refer to moving the trailers/containers between the IMF and 

beginning or end destination. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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Intermodal facilities have proven to be an economic growth 

engine.345 For example, since opening in 1989, a smaller 

IMF at the Virginia Inland Port in Front Royal, Virginia, has 

resulted in $600 million in investment, 27 major companies 

locating nearby, and over 7,000 created and benefited 

jobs.346 Front Royal, Virginia, is in a rural area.347

Economic growth and benefits are likewise expected from 

the Memphis Regional IMF. 

Potential secondary cumulative impacts include the 

expansion or establishment of existing and new market 

areas along with greater product profits accruing from 

lower transportation costs. Other secondary cumulative 

impacts include the potential attraction of business and 

industry to Fayette and Marshall Counties because of the 

access to the IMF. 

3.18.5 Indirect and Cumulative Impacts to Terrestrial 

Resources 

3.18.5.1 Indirect Impacts 

Indirect impacts of the Memphis Regional IMF on terrestrial 

resources include alteration of farmlands and forested 

habitats through conversion to support secondary 

development. As noted in Section 3.12.1, following 

minimization and avoidance measures, the project will 

impact approximately 244 acres of forested habitat, 

approximately 206 acres of non-forested habitat, including 

waters and wetland habitat on site, necessary to meet the 

purpose and need of the project. Mobile organisms from 

disturbed areas of the site location are expected to 

colonize adjacent lands, which include similar habitat as 

on-site terrestrial resources. 

The Memphis Regional IMF, Rossville, and north of 

Piperton, Collierville, Germantown, etc. are within the Wolf 

River Watershed (HUC 08010210). The project area is 

within the HUC-12 Wolf River Subwatershed of 0301. This 

subwatershed consists of three waterbodies: Hurricane 

Creek, Unnamed Tributary to Wolf River, and Russell 

Creek. The project site is within the Unnamed Tributary to 

Wolf River (TN0801020004-0400), Figure 3-40.348 The 

majority of the subwatershed is in Tennessee, but the 

drainage area starts in Mississippi. 

 

345 NS Crescent Corridor Fact Sheet. http://www.thefutureneedsus.com/images/pdf/memphis-factsheet.pdf. 

346 NS Crescent Corridor Fact Sheet. http://www.thefutureneedsus.com/images/pdf/mccalla-factsheet.pdf. 

347 Town of Front Royal, Virginia Comprehensive Area Plan Update: North East, Happy Creek, Leach Run Planning 

Areas, January 2008. 

348 TDEC, 1 August 2007, Total Maximum Daily Load (TMDL) for E. Coli in the Wolf River Watershed (HUC 08010210) 

Fayette, Hardeman, and Shelby Counties, Tennessee. 
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Figure 3-40: Wolf River Watershed 

The part of the Industrial Road and the Developer’s 

proposed commercial/industrial develop along Industrial 

Road, south of Piperton, Collierville, Germantown, etc., 

and Chickasaw Trail Industrial Park is within the 

Nonconnah Creek Watershed (HUC 08010211), Figure 3-

41.349 The majority of the subwatershed is in Tennessee, 

but the drainage area starts in Mississippi. 

Figure 3-41: Nonconnah Watershed 

 

349 TMDL for Chloridane, Dioxins, and PCBs in Nonconnah Creek, Shelby County, Approved by EPA June 10, 2009. 
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Figure 3-42 illustrates the percentage of land use by 

categories, within the HUC-12 Subwatershed 0301.350

Figure 3-42: Area Land Use (Percentage) within Drainage Areas 

Figure 3-43 illustrates the area by acres of land use by 

categories, within the HUC-12 Subwatershed 0301.351

Figure 3-43: Area Land Use (Acres) within Drainage Areas 

As noted in Section 3.1.2 and in the indirect and 

cumulative impacts to land use in Section 3.18.1., 

development induced by the Memphis Regional IMF is 

 

350 TDEC, 1 August 2007, TMDL for E. Coli in the Wolf River Watershed. 

351 TDEC, 1 August 2007, TMDL for E. Coli in the Wolf River Watershed. 
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expected to include light industrial, including warehousing, 

and residential development to accommodate job growth. 

Other commercial service/support businesses, such as 

restaurants and gas stations, are anticipated to locate 

along US Hwy 72 due to the anticipated development. 

This development indirectly caused by the Memphis 

Regional IMF could cause some loss of wildlife habitat. As 

a percentage of total habitat and farmland, the secondary 

impact is expected to be insignificant due to the very large 

amount of both farmland and forest habitat in the project 

vicinity. 

The types of indirect impacts are similar to the direct 

impacts to the terrestrial resources as described in Section 

3.12.1. Plant communities found in the area are 

characteristic of communities formed over loess deposits 

including upland forested communities dominated by 

various oaks (i.e., white oak [Quercus alba], southern red 

oak [Q. falcata], post oak [Q. stellata], and black oak [Q. 

velutina]) and other hardwoods including sweetgum 

(Liquidambar styraciflua), yellow-poplar (Liriodendron 

tulipifera), black locust (Robinia pseudoacacia), black 

cherry (Prunus serotina), and slippery elm (Ulmus rubra). 

River birch (Betula nigra), American sycamore (Platanus 

occidentalis), red maple (Acer rubrum), box elder (Acer 

negundo), and green ash (Fraxinus pennsylvanica) are 

common along drainages and in floodplain areas.352

3.18.5.2 Cumulative Impacts 

The area adjacent to the proposed Memphis Regional IMF 

is zoned for industrial activity and accordingly it is possible 

that some of the warehousing and industrial economic 

development spurred by the Memphis Regional IMF would 

result in cumulative impacts to terrestrial resources in the 

local vicinity of the project. The conversion of this land to 

other uses, such as industrial or commercial, would result 

in the loss of wildlife habitat from the area. However, as 

the area is zoned for industrial use these impacts would be 

likely to occur regardless of the Memphis Region IMF. The 

types of impacts include those described in direct and 

indirect impacts related to alteration of terrestrial resources 

including farmlands and forested habitats through 

conversion to development. 

Because the project is located in an area already planned 

for growth, the cumulative impacts can be controlled and 

would likely be localized. As noted in Section 3.1.1, the 

project vicinity has been experiencing significant growth in 

warehousing, one of the secondary development types 

 

352USDA, “The Plants Database,” 28 Dec 2009 http://plants.usda.gov. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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anticipated to be induced by the Memphis Regional IMF. 

Several industrial parks have recently been established in 

the area, such as the Chickasaw Trail Industrial Park (an 

independent development), which is likely to have 

businesses which would utilize the Memphis Regional IMF. 

Patterns of land use could be changed by the projected 

growth in the region, and accordingly the cumulative 

impact on terrestrial resources can be controlled through 

policies on density and development. The Fayette County 

Growth Plan353 encourages compact and contiguous high 

density development and promotion of economic health 

and employment opportunities, such as those land uses 

that would be directly and indirectly induced by the 

Memphis Regional IMF, and accordingly cumulative 

impacts to terrestrial resources can be controlled. Local 

governments can manage the level of these impacts 

through zoning and regulations. 

In rural areas, such as these portions of Fayette and 

Marshall Counties, the amount of forested habitat is 

decreasing.354 Much of the area in the vicinity of the 

project has already been cleared for agricultural and 

residential uses. With the large amount of agricultural and 

forested lands in Fayette and Marshall Counties, the 

cumulative impacts would be offset by other available 

terrestrial resources and habitat. After project 

construction, areas that remain undisturbed within the 

property boundaries, would, overtime, provide refuge for 

local wildlife as the surrounding area becomes more 

urbanized and habitats are altered.

3.18.6 Indirect and Cumulative Impacts to Wetlands, Water 

Quality and Aquatic Resources 

3.18.6.1 Indirect Impacts 

As noted in Section 3.18.1 and 3.18.3, indirect effects 

include land use changes due to economic development 

that would be indirectly induced by the Memphis Regional 

IMF. Within Shelby County, any indirect residential, 

industrial, or commercial development can be expected to 

be absorbed within the county’s larger population and 

industrial centers. The primary impacts to wetlands, water 

quality, and aquatic resources would be limited to 

construction related impacts such as potential sediment or 

suspended solids impacts to water quality, and potential 

impacts to streams or other waterbodies. 

 

353 Fayette County, 2003. 

354 Personal Communication with Fayette County Cooperative Extension Service and Marshall County Cooperative 

Extension Service, October 2009. 
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Due to the types of commodities expected to be 

transported through the Memphis Regional IMF, with a 

very low percentage of shipments considered hazardous 

under DOT hazardous materials regulations, indirect, postconstruction, effects on water quality, wetlands, and water 

resources would be minimal. One potential area of impact 

includes stormwater. Under EPA and TDEC regulations 

and guidance, these types of developments are typically 

not considered significant sources of pollutants and 

accordingly the agencies do not include operational 

permits or regulatory provisions for individual residences or 

the type of industrial activities likely to be indirectly induced 

by the proposed Memphis Regional IMF.355 A NPDES 

Stormwater Permit for Construction would be required for 

these developments, if more than one (1) acre of land 

would be disturbed during construction activities.356

If water quality issues are identified with respect to these 

future indirect developments, the agencies have authority 

to specifically address the issues through requiring NPDES 

permits. Some municipal stormwater discharges related to 

indirect development are likely to fall within areas subject 

to EPA and TDEC’s municipal separate storm sewer 

system (MS4) program357, which includes BMP and other 

conditions to limit impacts on water quality. The regulatory 

authority extends to protection of the Memphis Sands and 

other similar type aquifers. Indirect impacts based on the 

Memphis Regional IMF are subject to Local, State and 

Federal regulatory programs to protect water quality and 

water resources, though an aquifer specific permit is not 

required for construction within the aquifers’ recharge 

zones within Tennessee or Mississippi. 

With respect to development and construction related 

impacts, development and construction will be subject to 

Local, State and Federal regulatory programs to protect 

water quality, wetlands, and water resources. On a State 

and Federal level, all development is subject to regulatory 

programs such as the CWA and the State ARAP 

programs, which protect water quality by requiring new 

development to meet water quality standards, and where 

alterations to waters cannot be avoided, mitigation to 

provide for restoration of lost aquatic resource benefits. 

TDEC’s ARAP program is nationally recognized for its 

comprehensive protection of water resources. The ARAP 

program includes both wetland and water quality protective 

measures during permitting and construction, and 

mitigation such that there is no net reduction in water 

 

355 40 C.F.R. § 122.26 

356 TN NPDES TNR100000. 

357 TDEC, http://www.tennessee.gov/environment/wpc/stormh2o/MS4.shtml. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

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habitat function following development.358 Industrial, 

commercial, and residential developments are subject to 

construction permits such as the Federal CWA Section 404 

permit program protecting waters of the U.S. are 

administered by the USACE, which requires compliance 

with water quality standards and a water quality 

certification from the TDEC. Like the ARAP program, the 

Section 404 program includes both protective measures 

during project design, including avoidance and 

minimization of impacts to regulated waters, as well as 

comprehensive mitigation requiring the replacement of lost 

water and wetland ecosystem functions and in some cases 

enhancement of such functions.359 As noted above, the 

CWA NPDES requires compliance with water quality 

standards as a basic and essential requirement of all 

regulated discharges. An integral part of the NPDES 

program are associated watershed assessments, water 

quality management plans, Section 303(d) and 305(b) 

water quality assessments and reports provided to EPA by 

TDEC, and implementation measures described in detail in 

the cumulative impacts section below. 

In addition to the numerous levels of protection of water 

quality, wetlands, and water resources, the areas most 

likely to experience indirect development from the 

proposed Memphis Regional IMF have additional 

protective requirements and measures in place to address 

water, wetland, and water resource impacts. Fayette 

County ordinances include restrictions on subdivisions 

which require assessment of hydrology to address 

potential impacts from peak flows and other stormwater 

management related impacts.360 For subdivision 

developments subject to local ordinances and regulations, 

the County also includes provisions intended to address 

recharge and potential impacts to aquifers such as the 

Memphis Sand.361 

In addition to the State and Federal requirements 

protecting water quality and wetlands identified above, 

Shelby County ordinances also provide for specific water 

quality and construction related protective measures.362 

Protective measures include peak flow protection, buffers, 

and other general stormwater management provisions and 

protective measures. 

 

358 USACE and EPA’s Final Rule on Compensatory Mitigation for Losses of Aquatic Resources (April 10, 2008) issued 

pursuant to Section 404 of the CWA, 22 U.S.C. § 1344, and regulations at 33 C.F.R. and 40 C.F.R. 230. 

359 USACE, Memphis District, Section 404 Program, http://www.mvm.usace.army.mil/regulatory/; Mitigation Guidelines, 

http://www.mvm.usace.army.mil/regulatory/guidelines/mitigation_guidelines.htm. 

360 Fayette County Ordinances, Section 4-105. 

361 Fayette County, “Subdivision Regulations of Fayette County, Tennessee,” January 2008. 

362 County Code of Shelby, Tennessee, Chapters 29 and 30, (Codified through Ordinance No. 373), enacted 1 Jun 2009. 
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In Marshall County, Mississippi, all new development 

would be subject to the State and Federal provisions 

identified above, except that NPDES and State 

construction and water quality protective measures are 

administered by the Mississippi Department of 

Environmental Quality (MDEQ).363 Because MDEQ’s 

NPDES program is a part of the Federal CWA NPDES 

program, the protective measures for development and 

construction in Mississippi should be at least as stringent 

as the Federal program and similar to those in Tennessee 

administered by TDEC. 

3.18.6.2 Cumulative Impacts 

Cumulative impacts associated with the proposed project

would include the incremental impacts of the proposed 

Memphis Regional IMF on water, wetlands, and water 

resources when added to past, present, and reasonably 

foreseeable future changes in water, wetland, and water 

resources within the areas potentially affected by the 

project. As noted in Section 3.18.1, the area has 

experienced and is anticipating residential, industrial, and 

commercial development and growth which would place 

increasing pressure on wetlands, water quality, and 

aquatic resources. Fayette County, which has significant 

rural and agricultural lands, would experience conversion 

of agricultural lands and forested areas to accommodate 

residential, industrial, and commercial development. 

Similar growth patterns have been experienced in Marshall 

County, Mississippi, which would also likely see some 

increased conversion of agricultural and forested areas to 

development, although less is known regarding future 

growth patterns in Marshall County. Shelby County is 

already a significant suburban center with relatively stable 

population and development centers. 

For efficient operation and to support the needed 

equipment, an intermodal facility (approximately 380 acres) 

requires a relatively flat, paved surface (approximately 233 

acres). Grading activities and subsequent paving can alter 

groundwater recharge and runoff characteristics as 

compared to the previous forested, agricultural, and natural 

habitats. The proposed Memphis Regional IMF footprint 

would be very small compared to the overall recharge area 

of the Memphis Sands aquifer and therefore its effect on 

groundwater recharge in the area would be insignificant. 

Compacted clayey soil below the facility combined with the 

roller-compacted concrete surface and stormwater controls 

are expected to provide ample protection to the 

groundwater resource of the area. 

 

363 MDEQ, Storm Water http://www.deq.state.ms.us/MDEQ.nsf/page/epd_epdgeneral
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Secondary development in the area could result in 

additional cumulative impacts to wetlands, water quality 

and other aquatic resources. As noted in Section 3.1.1 

and in the Ecology Report, lands in the project vicinity are 

previously disturbed and include forested, shrub/scrub 

thickets, pasture, agricultural and rural residential areas. It 

is unclear if the previous land disturbing activities in the 

area impacted the quantity or quality of groundwater. 

Secondary development could add to reduced recharge to 

the aquifer and to the potential for impacts to groundwater 

quality. These impacts would result from a loss of pervious 

ground and associated infiltration and potential releases of 

contaminants in areas where infiltration does occur. 

Through regulation and ordinance local government would 

need to control such development and potential impacts 

Industrial Road construction is expected to open the area 

south of the project to additional commercial and industrial 

development. Future development would require future 

construction and its related impacts, and may potentially 

increase impervious surfaces in the immediate project 

area. 

Future industrial development would most likely be located 

within existing or planned areas within the three counties 

most likely to experience induced development related to 

the Memphis Regional IMF. For Fayette County, the 

industrial corridor established by the Fayette County 

Growth Plan, and residential development is most likely to 

occur in those areas designated as such in the Growth 

Plan.364 In Shelby County, with its significant existing 

development and large, stable population, it is anticipated 

that residential and industrial development would occur 

within established areas in the county and/or in areas 

identified by the county’s zoning and land use ordinances. 

In Marshall County, the county has been involved in 

developments such as the Chickasaw Industrial Park. 

Industrial development would be anticipated to occur within 

the Industrial Park area with its infrastructure and location 

benefits. Residential development locations are not limited 

in Marshall County. 

The conversion of lands to agricultural, commercial, and 

industrial development would result in cumulative impacts 

to wetlands, water quality and aquatic resources. Land 

use and zoning provisions in both Fayette County, 

Tennessee and Marshall County, Mississippi require that 

development will not endanger any water supply can 

reduce potential cumulative impacts.365 The ecosystem in 

 

364 Fayette County, 2003. 

365 Fayette County, 2003. Marshall County, 2007. 
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the vicinity of the project and in areas expected to 

contribute to cumulative effects are within the Coastal Plain 

physiographic unit and the Wolf Watershed (HUC 

08010210) and the Nonconnah Creek Watershed (HUC 

08010211)366 (Figure 3-44). Both drain into the Mississippi 

River.367 The watershed approach recognizes that waters 

of the State do not follow State or County boundaries. The 

Memphis Regional IMF is in the Wolf River Watershed, 

while the commercial/industrial zoned developments in 

Mississippi are in the Nonconnah Creek Watershed. 

Figure 3-44: West Tennessee Watersheds 

TDEC assessed resources based upon land use allocation 

by watershed and included the results in TDEC’s water 

quality management plans.368 In the western portion of the 

watershed, the Wolf River and Nonconnah Creek have 

experienced significant urbanization and areas of high 

intensity residential, industrial, and commercial 

development. Figure 3-45 displays land use 

characteristics of the Wolf River Watershed.369 Figure 3-

46 displays land use characteristics of the Nonconnah 

Creek Watershed.370

 

366 TDEC, 9 November 2000, Nonconnah Creek Watershed (08010211) of the Mississippi River Basin Water Quality 

Management Plan. 

367 TDEC West Tennessee Watersheds 

http://www.tn.gov/environment/watersheds/watershedsigns/regional/west_wshed_map.shtml. 

368 TDEC, Watershed Management http://tennessee.gov/environment/watersheds/index.shtml. 

369 TDEC, August 2007, Total Maximum Daily Load (TMDL) for E. Coli in the Wolf River Watershed (HUC 08010210) 

Fayette, Hardeman, and Shelby Counties, Tennessee.

370 TDEC TMDL PCB June 10, 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE 

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Figure 3-45: Land Use Characteristics of the Wolf River Watershed (HUC 0801210) 
3 ENVIRONMENTAL CONSEQUENCES OF THE 

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Figure 3-46: Land Use Characteristics of the Nonconnah Creek Watershed (HUC 08012
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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In terms of current land use distribution, as noted in 

Section 3.18.1, a significant portion of the area is 

agricultural lands previously converted. Figure 3-47 

graphically displays land use for the Wolf River 

Watershed.371 Figure 3-48 graphically displays land use 

for the Nonconnah Creek Watershed.372

Figure 3-47: Land Use by Percentage for Wolf River Watershed 

Figure 3-48: Land Use by Percentage for Nonconnah Watershed 

 

371 TDEC, TMDL Wolf River PCBs, December 13, 2007. 

372 TDEC, TMDL Nonconnah Creek PCBs, June 10, 2009. 
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Current water quality issues exist in the area unrelated to 

the Memphis Regional IMF. In 2007, TDEC has published 

and EPA approved a TMDL for E. Coli in the Wolf River 

Watershed (HUC 08010210) in Fayette, Hardeman, and 

Shelby Counties in Tennessee.373 This includes the 

Unnamed Tributary to Wolf River (TN0801021004-0400) 

within the IMF footprint and part of Industrial Road. 

 Within the watershed five (5) NPDES permitted 

wastewater treatment facilities (WWTFs) in the 

impaired subwatersheds of the Wolf River watershed 

authorized to discharge treated sanitary wastewater 

during the TMDL analysis period. Four of the 

facilities are sewage treatment plants (STPs) serving 

municipalities and all four (Memphis-Maynard C. 

Stiles STP [TN0020711], Collierville STP 

[TN0057461], Rossville STP [TN0064092], and the 

Collierville Northwest STP [TN0074543]) are major 

facilities with design capacities equal to or greater 

than 1.0 million gallons per day (MGD). 

 Non-permitted point sources of (potential) E. coli 

contamination of surface waters include wildlife, 

agricultural animals, failing septic systems, and urban 

development from stormwater discharges, illicit 

discharges, and domestic animals. 

The Wolf River Watershed is identified as part of Group 3 

watershed assessment, and the Nonconnah Creek 

Watershed is identified as part of Group 1. In accordance 

with the water quality management plan, TDEC plans to 

conduct routine watershed assessments for the purpose of 

protecting water quality and providing information on which 

to tailor its regulatory programs such as the NPDES under 

the Federal CWA, and the State’s ARAP program. If the 

cumulative effects of future actions result in impairments to 

water quality, under NPDES programs and requirements, 

water quality improvement implementation plans will be 

included in new or revised permits and addressed through 

State non-point source programs under Section 319 of the 

CWA and other State authorities. The CWA and TDEC’s 

antidegradation provisions require that any new 

development refrain from negatively impacting water 

quality with a narrow exception following an assessment of 

impacts and alternatives. TDEC’s watershed approach is 

intended to provide comprehensive assessment and tools 

to address future cumulative impacts on the watershed.

 

373 TDEC Wolf River E. Coli TMDL, August 2007 
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The State of Tennessee, in conjunction with environmental 

conservation organizations such as the Tennessee 

Environmental Council and the Wolf River Conservancy, 

are expected to continue their efforts toward the protection 

of wetlands, water quality, and aquatic resources. The 

Wolf River Conservancy has been assisting in the 

development and acquisition of properties along the Wolf 

River and its tributaries in development of a greenway to 

protect water quality, waterways and buffers.374 It is 

anticipated that these efforts would continue to protect high 

quality waters in the area. 

The closest State designated natural areas to the project 

are Ghost River Designated State Natural Area375 between 

Moscow and La Grange, Wolf River State Natural Area & 

Wildlife Management Area376 south between Moscow and 

La Grange, and William B Clark Designated State Natural 

Area377 northeast of Rossville; however, none of these 

areas are within the project boundary or down-gradient of 

the project. 

All industrial and residential development that may be 

induced by the Memphis Regional IMF is subject to 

Federal and State laws protecting water quality, wetlands, 

and water resources. As noted in indirect impacts above, 

due to the nature of IMF transportation, impacts are 

expected to be limited to construction and development, as 

the types of industrial development which may be induced 

by the proposed Memphis Regional IMF would likely fall 

within categories which are not considered to have 

substantial industrial stormwater pollutant contributions. 

As discussed in 3.18.1.2, the commercial and industrial 

developments that normally follow the intermodal facilities 

are warehouses and distribution centers. Intermodal 

facilities do not normally attract heavy manufacturing or 

industries that use or generate hazardous materials. 

TDEC and MDEQ have the authority to designate a 

particular stormwater source as requiring a stormwater 

permit if impacts are determined to be significant or 

otherwise affect water quality. With respect to other 

development not related to the proposed Memphis 

Regional IMF, due to regulatory programs protecting water 

quality, wetlands and water resources described in the 

 

374 Wolf River Conservancy, http://www.wolfriver.org/; An Introduction to the Wolf River, 

http://www.wolfriver.org/images/stories/information/introduction%20to%20wolf%20text.pdf

375 TDEC, Resource Management Division, http://tennessee.gov/environment/na/natareas/ghostriver/. 

376 TWRA, Wildlife Management Area, http://tennessee.gov/twra/gis/wmapdf/WolfRiver.pdf. 

377 TDEC, Resource Management Division, http://tennessee.gov/environment/na/natareas/wbclark/. 
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section, these resources will be subject to periodic 

assessment and issuance or revision of permits requiring 

compliance with water quality standards established by the 

States of Tennessee and Mississippi. Accordingly, 

sufficient regulatory methods are in place such that the 

cumulative impact of reasonably foreseeable future actions 

should not result in impacts or significant degradation of 

water quality, wetlands, or water resources. 

Tennessee and Mississippi have wellhead protection 

programs to protect public water systems/wells using 

ground water from contamination.378 All public water 

systems are required to prepare wellhead protection plans. 

Piperton, Collierville, and Rossville in Tennessee provide 

public drinking waters supplies. Communities establish 

wellhead protection areas and plan to manage potential 

contamination sources within the wellhead protection area. 

Wellhead protection programs help to reduce cumulative 

impacts on ground water. Local communities can 

participate in additional wellhead and aquifer protections 

through Local, State and Federal regulations including the 

Safe Drinking Water Act, 42 U.S.C. §§ 300f to 300j-26. 

3.18.7 Indirect and Cumulative Impacts to Floodplains 

3.18.7.1 Indirect Impacts 

The Memphis Regional IMF is located so as to avoid any 

direct impact to floodplains, as the location is outside of the 

Wolf River floodplain and areas identified in special flood 

hazard designated Zone A (Section 3.12.5). Like most 

communities, the areas most likely to experience indirect 

economic growth and development have ordinances 

limiting development within floodplains in accordance with 

the National Flood Insurance Program (NFIP).379 As noted 

in Section 3.18.7, ordinances limiting peak stormwater 

flows would effectively limit indirect impacts to floodplains 

from indirect development. 

3.18.7.2 Cumulative Impacts 

Cumulative impacts associated with the proposed project 

would include the incremental impacts of the proposed 

Memphis Regional IMF on floodplains when added to past, 

present, and reasonably foreseeable future changes in 

floodplains within the areas potentially affected by the 

project. Reasonably foreseeable growth and development 

unrelated to the project could impact floodplains; however, 

 

378 Tennessee, Drinking Water Supply Rule, 1200-5-1-34. Mississippi, Surface and Groundwater Use and Protection, 

379 City of Piperton, Urban Growth Boundary Report, May 2001; County Code of Shelby, Tennessee, 

Chapter 30, Section 30-46 Policy Statements for Development, enacted 6 December 2004; Town of Collierville Code of 

Ordinances, 151.090: Zoning Regulations.
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as noted above the areas most likely to experience indirect 

economic growth and development have ordinances 

limiting development within floodplains in accordance with 

the NFIP. While it is possible that non-conforming projects 

could receive approval for development, NFIP 

recommendations require assessment to floodplains and 

mitigation measures to minimize or avoid floodplain 

impacts. Figure 3-49 listed the FEMA map numbers for 

the sheets within southwest Fayette County.380 

Figure 3-49: FEMA Map Index for Southwest Fayette County 

Ordinances limiting peak stormwater flows would 

effectively limit indirect impacts to floodplains from indirect 

development. For example, Chickasaw Trails Industrial 

Park, a neighboring commercial/industrial development, 

and the projected development along Industrial Road, 

have covenants, which restrict and guide development 

within their community.381 These covenants include: 

 

380 FEMA map # 47047CIND0A http://map1.msc.fema.gov/idms/IntraView.cgi?KEY=78355964&IFIT=1 

381 Covenants of Chickasaw Trail Industrial Park as Amended: March 3, 2005 and August 4. 2005. 
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 Front setback on all buildings of at least one 

hundred (100) feet from the front property line 

bordering on any road or street; other setbacks 

minimum of twenty-five (25) feet. 

 Buffer areas along property lines for landscaping, 

drainage and utility easements, sidewalks, signage, 

street furnishings and hardware. 

 Requirement to leave untouched as much as 

possible the existing vegetation and natural 

amenities of the terrain. 

 Receive approval for any proposed clearing or 

vegetation removal. 

 Receive approval injure, remove or destroy any live 

trees over 6” in caliper (diameter). 

 Attractively landscaped and maintained to create a 

landscape buffer along all property lines. 

 Constructed all driveways and parking areas to 

include adequate drainage facilities to dispose of all 

stormwater. 

 Prohibit the discharge of untreated industrial 

wastes into a stream or open or closed drains. 

 Receive approval by the applicable governing body 

and the appropriate state and federal agencies for 

all methods of industrial sewage and solid waste 

treatment and disposal. 

 Strict adherence with regulations of state and 

federal law for discharge volume, quality, and 

strength of all liquid waste. 

 Prohibited uses include junkyards or salvage yards; 

rubbish, garbage, or trash dumps; asphalt/concrete 

manufacture; manufacture or storage of explosives, 

fireworks, or gunpowder; slaughterhouses or 

stockyards; and manufacture of celluloid pyrosylin 

or pyroxylin products. 

The watersheds within the cumulative impact area are the 

Wolf River, Nonconnah, and Upper Coldwater River 

Watersheds, Figure 3-50. 

The Wolf River Watershed is divided into three 10-digit 

HUC subwatersheds. The Memphis Regional IMF, 

Rossville, and north of Piperton, Collierville, Germantown, 

etc. are in the 10-digit HUC Wolf River Subwatershed 

(0801021003), the largest of the three. This subwatershed 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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covers 227,618 acres.382 A further division of the 

watershed places the IMF, Rossville, and Piperton in the 

12-digit HUC subwatershed of 0301 (080102100301). The 

0301 subwatershed has contributing drainage area on both 

sides of the Wolf River (43,204 acres). 

Figure 3-50: 12-Digit HUC Subwatersheds 

 

382 Insert WR TMDL E. Coli study reference 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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The part of Industrial Road and the Developer’s proposed 

commercial/industrial development along Industrial Road, 

south of Piperton, Collierville, Germantown, etc. and 

Chickasaw Trail Industrial Park are within the Nonconnah 

Creek Watershed (HUC 08010211). The majority of the 

subwatershed is in Tennessee, but the drainage area 

starts in Mississippi. This subwatershed covers 177,412 

acres.383

Additionally, where a development requires authorization 

under Section 404 of the CWA, assessment of floodplain 

impacts and consideration of mitigation measures to 

floodplain impacts is required consistent with EO 11988 

and the 404(b) public interest review process. In light of 

the restrictions and regulatory provisions relating to 

floodplain impacts, no reasonably foreseeable adverse 

cumulative impacts to floodplains are expected. 

3.18.8 Indirect and Cumulative Impacts to Noise 

3.18.8.1 Indirect Impacts 

Indirect noise impacts would potentially occur with respect

to secondary development induced by the Memphis 

Region IMF. However, such development is not expected 

to have substantial noise impacts. It is anticipated that a 

primary type of indirect development induced by the 

Memphis Regional IMF would include warehousing, a form 

of light industrial use which typically has low level noise 

impacts. As noted in Section 3.18.1, it is anticipated that 

the location of secondary development would be within 

industrial parks and/or locations designated and zoned for 

industrial development, which would mitigate for noise 

impacts potentially affecting receptors such as residences. 

3.18.8.2 Cumulative Impacts 

Cumulative impacts associated with the proposed 

Memphis Regional IMF would include the incremental 

impacts on the noise environment when combined with 

reasonably foreseeable future changes in noise in the 

vicinity of the project. The noise technical analysis 

assessed direct impacts from the proposed Memphis 

Regional IMF and predicted impacts in the design year 

2032.384 The analysis concluded that direct noise impacts 

associated with the Memphis Regional IMF would be minor 

and within acceptable levels. Any cumulative noise 

impacts in the immediate vicinity of the Memphis Regional 

IMF would need to be considered and evaluated based on 

 

383 TDEC TMDL Nonconnah Creek, Jun 10, 2009 

384 AMEC Earth & Environmental, “Memphis Regional Intermodal Facility, Noise Analysis,” December 2009, On file with 

TDOT (Nashville, TN: AMEC). 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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the noise emission characteristics of the proposed 

developments. 

The noise technical analysis concluded that due to 

anticipated growth in vehicle traffic resulting from planned 

growth in the Rossville UGB and Chickasaw Trail Industrial 

Park Development (an independent development)385 area 

along US Hwy 72, that traffic noise levels were anticipated 

to increase by up to 2 dBA without development of the 

proposed Memphis Regional IMF. The addition of traffic 

supporting the Memphis Regional IMF is not expected to 

appreciably increase the noise levels along US Hwy 72, 

with minor traffic noise increases of 1 or 2 dBA higher than 

the No-Build scenario. 

Considering the rule of thumb that doubling of the sound 

energy produces a 3 dBA sound level increase, a change 

that is barely perceptible to human hearing, the traffic; 

therefore, general development in the US Hwy 72 corridor, 

would have to increase more than double from the 

predicted volumes in 2032 to noticeably increase 

cumulative future traffic noise levels. 

3.18.9 Indirect and Cumulative Impacts to Cultural 

Resources 

3.18.9.1 Indirect Impacts 

As noted in Section 3.18.1, economic growth related to the 

proposed Memphis Regional IMF would potentially support 

residential and light industrial development in the project 

vicinity within Fayette, Shelby, and Marshall Counties. 

Indirect impacts related to secondary development are 

possible but the potential for indirect impacts is minimized 

due to the fact that land use and zoning provisions, as well 

as established industrial park areas, would limit industrial 

development to specific geographic areas. A historical and 

cultural resource study for the Memphis Regional IMF was 

conducted and in consultation with the SHPO it was 

determined that on-site impacts to cultural and historic 

resources were not substantial. A records search was 

conducted around Industrial Road, which is being 

independently constructed but would be utilized by the 

proposed Memphis Regional IMF and other industrial 

businesses. No archaeological resources either listed or 

eligible for listing on the NRHP were identified. In terms of 

significant cultural or historic resources in the vicinity of the 

proposed project, the cultural resources report identified 

 

385 Marshall County Economic Development Authority, http://www.marshallcoms.com/Chickasaw_Trail/chickasaw.html. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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the Rossville Historic District386 as a potentially significant 

resource. 

Secondary development in the area surrounding the 

proposed intermodal facilities could result in additional 

impacts to unknown or undiscovered archaeological 

resources in the area. However, because it is not known 

where the development would occur, additional surveys 

would not be useful at this time. 

Additional private development would not generally be 

required to comply with the cultural resource protections 

afforded by Section 106 for Federal actions. However, the 

SHPOs do afford a level of historic preservation and 

protection. 

3.18.9.2 Cumulative Impacts 

Any sites disturbed during construction of this project 

would add to the overall disturbance to archaeological 

resources from all past, present, and future construction 

projects in the area. All efforts will be made to avoid 

impacts to cultural resources. If any unknown cultural 

resources are discovered during construction, all activities 

in the immediate area would cease and the SHPO would 

be notified to determine the significance of the site. If 

potentially significant, the Tennessee Division of 

Archaeology and the American Indian tribes with interests 

in the area would be immediately contacted so that 

representatives may have the opportunity to examine and 

evaluate the materials.

3.18.10 Indirect and Cumulative Impacts from Hazardous 

Materials

3.18.10.1 Indirect Impacts 

With respect to the commodities that may be transported 

through the Memphis Regional IMF, only very small (an 

estimated 3-4%) amounts of the total shipments could be 

hazardous.387 Furthermore, NSR does not move toxicinhalants and other certain classes of hazardous materials 

by intermodal freight. 

No known hazardous waste sites exist onsite or nearby. 

Therefore, indirect impacts associated with existing 

hazardous waste sites would not occur. 

 

386 National Park Service, National Register of Historic Places, 2001, 

http://www.nationalregisterofhistoricplaces.com/TN/Fayette/state.html.

387 NS Technical Memo, Subject Memphis Regional Intermodal Facility – HazMat Traffic, dated January 15, 2010. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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As noted in Section 3.1.1, the Memphis Regional IMF is 

likely to stimulate secondary economic development, but 

the nature of intermodal commodities and the IMF 

operation are such that it would be unlikely that businesses 

with large hazardous materials usage would be attracted 

by the presence of the Memphis Regional IMF. As 

discussed in Section 3.18.1.2, the types of development 

that normally follow the intermodal facilities are 

warehouses and distribution centers. Intermodal facilities 

do not normally attract heavy manufacturing or industries 

that use hazardous materials. Service businesses, such 

as gas stations, could locate in the area. Gas stations 

store petroleum or diesel fuel in underground storage 

tanks. Due to requirements for double walled tanks as well 

as leak detection systems, the potential for leaking 

underground storage tanks would be reduced. Any 

industrial development, which does include hazardous 

materials, would be subject to FRA, PHMSA, and RCRA 

regulations governing the storage, utilization, response to 

spills, and transportation and disposal of hazardous 

materials.388 

As noted in Section 3.16, NSR has available immediate 

response resources on a 24/7 basis and a variety of other 

Local, State and Federal response authorities are also 

available. The project is not expected to indirectly affect 

hazardous materials or hazardous waste sites. 

3.18.10.2 Cumulative Impacts 

Cumulative impacts associated with the proposed project

would include the incremental impacts of the proposed 

Memphis Regional IMF on hazardous materials and 

releases, when added to past, present, and reasonably 

foreseeable future changes in hazardous materials and 

releases within the areas potentially affected by the 

project. 

As noted in Section 3.16 and in the indirect impacts 

assessment above, the likelihood of potential cumulative 

effects on hazardous materials and releases of the 

Memphis Regional IMF is low. Federal, state and local 

hazardous materials and waste regulations establish 

requirements for generating/managing hazardous 

materials/wastes. Zoning requirements in Fayette and 

Marshall Counties limit the types of businesses and their 

potential hazards. Accordingly, it is not anticipated that 

there would be sustainable cumulative impacts relating to 

 

388 EPA 2008. RCRA Orientation Manual 2008: Resource Conservation and Recovery Act, Office of Solid 

Waste/Communications, Information, and Resources Management Division, 2008. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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hazardous materials at the proposed Memphis Regional 

IMF.

3.18.11 Indirect and Cumulative Impacts to Visual Effects 

3.18.11.1 Indirect Impacts 

Construction of the Memphis Regional IMF may induce 

supportive industrial and residential development which 

could generate visual impacts away from the project area. 

Depending on the resident’s view-shed, these impacts may 

or may not be viewed as negative. The impact is expected 

to be limited to those areas where land use change is 

anticipated, within the three county area identified in 

Section 3.18.1. 

3.18.11.2 Cumulative Impacts 

Cumulative impacts associated with the proposed project

would include the incremental impacts of the proposed 

Memphis Regional IMF on aesthetic or visual resources 

when added to past, present, and reasonably foreseeable 

future changes in visual or aesthetic resources within the 

areas potentially affected by the project. 

There would be limited potential for the Memphis Regional 

IMF to interact with other projects with regard to visual 

quality. The facility itself would be constructed with sight 

barriers or berms and screening vegetation, and would not 

further alter visual quality after construction is complete. 

The potential for an incremental contribution to reduction in 

visual quality would be limited by the screening vegetation, 

which would be compatible with the surrounding 

residential, industrial, and commercial development 

expected to be present. 

Long-term cumulative impacts to visual resources could 

occur when Build Alternative 1 is combined with the 

development occurring along Industrial Road, the 

proposed SR-57 overpass or US Hwy 72. Depending on 

the perception of the residents in the area, these viewshed 

impacts may or may not be considered adverse. 

3.18.12 Indirect and Cumulative Impacts to Air 

3.18.12.1 Indirect Impacts 

Short-term indirect air quality impacts could occur to the 

surrounding areas during construction due to the presence 

of construction vehicles and dust created during 

construction activities. Indirect air quality impacts are not 

anticipated to cause air quality standards to be violated. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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3.18.12.2 Cumulative Impacts 

Cumulative impacts associated with the proposed project 

would include the incremental impacts of the proposed 

Memphis Regional IMF on air when added to past, 

present, and reasonably foreseeable future changes in air 

within the areas potentially affected by the project. 

Locally, vehicle emissions would increase with growth in 

the region that would occur with or without the Memphis 

Regional IMF. Throughout the region, as additional 

businesses are built in response to this and other 

development in the region, there would be the potential for 

increases in air emissions over a multi-county area. 

However, controls on emissions related to current and 

future air quality standards imposed on the region would 

be expected to mitigate these increases. Additional 

requirements imposed on vehicles to control emissions 

also should minimize air quality impacts from the additional 

growth. 

For example, automobile manufacturers must meet 

corporate average fuel economy (CAFE) standards, which 

not only conserve fuel, but also reduce the motor vehicle 

tailpipe emissions of carbon dioxide, the principal GHG 

emitted by motor vehicles.389 The National Highway 

Traffic Safety Administration (NHTSA) estimates the CAFE 

standards established for model year 2011 cars and light 

trucks would save 887 million gallons of fuel and reduce 

GHG emissions by 8.3 million metric tons over the lifetime 

of these vehicles.390 In addition, the NHTSA and the EPA 

are jointly proposing to establish even stronger standards 

for passenger cars, light-duty trucks, and medium-duty 

passenger vehicles for model year 2012 through 2016 that 

would reduce carbon dioxide emissions by an estimated 

950 million metric tons and save 1.8 billion barrels of oil.391 

Regional transportation planning includes consideration of 

mobile source emissions. Operation of the Memphis 

Regional IMF would contribute to increased local 

emissions from trucks and decreased regional emissions 

from trucks. Transportation improvement projects, 

increased vehicle emission standards, and the expected 

increase in use of hybrid or other alternate fuel vehicles 

would result in decreased emissions on a per unit basis. 

 

389 “Average Fuel Economy Standards, Passenger Cars and Light Trucks Model Year 2011,” Final Rule, Federal 

Register Volume 74, No. 59, pages 14198 to 14242, 30 Mar 2009.

390 Average Fuel Economy Standards, Passenger Cars and Light Trucks Model Year 2011, Final Rule, Federal Register 

Volume 74, No. 59, pages 14198 to 14242, Monday, March 30, 2009. 

391 EPA 2009. Fact Sheet: EPA and NHTSA Propose Historic National Program to Reduce Greenhouse Gases and 

Improve Fuel Economy for Cars and Trucks, EPA-420-F-09-047a, September 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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The TDOT Long Range Planning Division has identified 

both Shelby County (Memphis) and Fayette County as 

priority counties for truck stop electrification sites. These 

sites provide truck drivers with alternatives to idling at truck 

stops in key freight traffic corridors and provide for an 

immediate positive impact on local air quality by reducing 

diesel exhaust emissions.392 

The net contribution of the Memphis Regional IMF to 

regional air quality through interaction with increased 

vehicle numbers in the region would likely be minor. 

Emissions during construction and operation of the 

Memphis Regional IMF will be in compliance with the 

NAAQS. 

New businesses and industries developed along Industrial 

Road, US Hwy 72, and SR-57 could generate air 

emissions and affect air quality. However, these 

businesses and industries would be required to comply 

with all applicable air quality laws and regulations. 

Increased development, such as new commercial storage 

or warehousing, along Industrial Road or US Hwy 72 would 

likely increase short-term local air pollution due to 

emissions from construction vehicles, equipment-related 

particulate emissions, and fugitive dust emissions. These 

impacts are anticipated to be minor and would be short 

term in nature. 

Cumulative air quality impacts could occur as a result of 

increased truck traffic on US Hwy 72; however, these 

impacts are anticipated to be minor as compared to overall 

traffic via this route and would be reduced as planned 

improvements to US Hwy 72 (increase to four lanes) are 

implemented. Therefore, Build Alternative 1 is not 

expected to result in negative cumulative impacts to air 

quality.393 

Evaluation of transportation energy use indicates that 

highway vehicles account for 80% of the total 

transportation energy use with 18.7% accounted for by 

medium and heavy trucks. Rail, specifically Class I freight 

rail, accounts for only 2.1% of transportation energy use, 

as illustrated in Figure 3-51.394 

 

392 TDOT 2009. Truck Stop Electrification Technology Grant Projects and associated Tennessee TSE Corridor map of 

priority areas, http://www.tdot.state.tn.us/environment/policy/tse.htm, October 2009. 

393 AMEC Earth & Environmental, “Memphis Regional Intermodal Facility, Air Quality Technical Report,” December 2009, 

On file with TDOT (Nashville, TN: AMEC). 

394 ORNL 2009. Transportation Energy Data Book: Edition 28, ORNL-6984, cta.ornl.gov/data. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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The transportation sector contributes approximately onethird of national carbon dioxide emissions.395 Because 

railroads are approximately three and a half times more 

fuel efficient than trucks on a ton-mile basis, the shipment 

of freight by rail has been shown to result in a 

corresponding decrease in carbon and other emissions. 

Given that the Memphis Regional IMF would handle an 

estimated 187,000 loaded containers and trailers per year 

by 2015 freight that would have otherwise gone via longhaul truck (between the Memphis region and Northeast 

U.S.), there would be a substantial reduction in carbon 

dioxide and other emissions on a national basis as a direct 

result of the increased efficiency of freight travel, and the 

associated reduction in fuel use that would be attributable 

to the operation of the Memphis Regional IMF. 

Figure 3-51: Transportation Energy Use by Transportation Mode 

The annual benefits attributable to the Memphis Regional 

IMF when it is fully operational in the year 2015 are 

expected to include nearly 187,000 long-haul truckloads 

diverted to rail, almost 23.8 million gallons of fuel saved, 

approximately 264,000 tons of carbon dioxide reduction, 

reduced costs for pavement maintenance ($16.1 million); 

reduced costs for highway delays ($81.4 million); reduced 

costs from fuel consumption and emissions ($20.9 million); 

reduced costs for highway crashes and fatalities ($20.7 

million); and increases in rail-related wages and job 

creation/saved ($91.2 million).396 The operation of the 

 

395 ORNL 2009. 

396 Analysis of Truck to Rail Diversion Benefits – Memphis, Cambridge Systematics, Inc., January 20, 2010. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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proposed Memphis Regional IMF would reduce highway 

congestion and would ultimately reduce air emissions, 

including GHG emissions on a national basis. 

3.19. Construction Impacts 

During construction of the Memphis Regional IMF, some 

impacts are expected including: utility relocations, 

construction-related traffic, access to roads and properties, 

noise, and air quality. These impacts would generally be 

temporary in nature but could affect local residents, 

businesses and travelers. Proper planning and 

implementation of controls should help alleviate these 

impacts. 

Construction impact controls would be integrated into the 

project’s contract specifications and traffic control plans to 

avoid or minimize these inconveniences. Consequently, 

the project would have physical construction-related 

impacts, but with implementation of appropriate controls, 

construction impacts are expected to be insignificant. 

The following construction issues are addressed below: 

 Maintenance of traffic and access; 

 Employment benefits; 

 Waste disposal; 

 Utility relocation; 

 Discovery of unknown archaeological sites; 

 Erosion control; 

 Air quality; 

 Noise; and 

 Natural resources. 

3.19.1 Maintenance of Traffic and Access 

Traffic would be maintained on existing roadways during 

construction or detours would be developed. Access to all 

properties would be maintained.

During construction, truck and construction equipment 

traffic and worker vehicles would enter and exit the site 

primarily from the adjacent property to the west and using 

Industrial Road and US Hwy 72. Approximately 100 heavy 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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vehicles and 120 worker vehicles would enter and leave 

the project area on a daily basis. Construction vehicle 

traffic on SR-57 would be limited to equipment necessary 

to construct the SR-57 overpass and the lead tracks from 

SR-57 north to the NSR mainline (approximately 0.1 mile). 

Also during this time, a temporary grade crossing of the 

lead tracks would be required along the SR-57 bypass. 

Approximately 30 to 40 work trains would use this crossing 

over an eight month period. Maximum work train 

frequency would occur when ballast is placed on track 

being constructed. During that period of construction, only 

one work train per day would use the crossing. Work train 

activity would be limited to daylight hours only and NSR 

would provide flagmen to warn the general public when the 

crossing would be occupied by a train. Industrial Road, 

US Hwy 72 and SR-57 are all designed for heavy truck 

traffic and should; therefore, experience little or no 

substantial damage due to construction-related traffic. 

3.19.2 Employment Benefits 

The construction timeframe for this project is estimated at 

two years. Construction activities may result in economic 

benefits to the local area during the period of construction 

that would include increased revenue to local businesses 

through the sale of construction supplies and materials and 

retail and service purchases by construction personnel.397 

Construction jobs would be available for persons residing 

in the area. These short-term revenues and jobs are 

expected to be beneficial but not expected to be locally or 

regionally substantial. 

It is not anticipated that any short-term adverse economic 

impacts would occur to individual local businesses due to 

construction of the SR-57 overpass. This work is not 

expected to cause major delays or traffic problems. SR-57 

would remain open during construction with a slight detour 

or bypass. Access to businesses on SR-57 in the 

immediate area may require a re-route but overall volume 

should not be affected. 

3.19.3 Waste Disposal 

Solid waste could be generated by project construction

(e.g., through demolition and removal of structures). The 

quantity of disposed waste would represent a negligible 

 

397 Insight, May 2009. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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proportion of the total that is currently directed toward local 

landfills.398 

Any toxic and hazardous materials would be handled and 

used in accordance with package labels and 

manufacturer’s directions. Wastes would be segregated, 

labeled, and stored in a manner that would prevent the 

release of hazardous constituents into the environment. In 

the unlikely event of a spill, emergency protocols for 

response would go into immediate effect including 

implementation of the contractor’s site specific spill 

prevention control and countermeasure (SPCC) plan. In 

accordance with the site specific SWPPP, the contractor 

would designate specific areas for fueling and minor 

maintenance of vehicles. The designated area would not 

be adjacent to streams, wetland, or exposed areas of 

Memphis Sand. The surface soils at vehicle areas would 

be checked daily for signs of spillage or staining. 

Temporary containment would be used as needed during 

fueling operations. Any fixed fueling station and/or tank 

storage would have a containment system to prevent 

runoff from potential spills or tank rupture. Spill kits would 

be readily available in these areas. Machinery would be 

serviced or repaired to prevent fluid leaks. Major 

maintenance of construction equipment would not occur on 

site. The contractor would dispose of waste materials and 

their containers in accordance with applicable State and 

Federal regulations.399

Disposal of excess material would be the responsibility of 

the contractor who would be contractually required to 

handle and dispose of the material in accordance with 

TDOT’s Standard Specifications for Road and Bridge 

Construction. 

3.19.4 Utility Relocation 

The relocation of utilities would be included in final design 

plans. The City of Rossville would prepare plans for the 

relocation of its utilities that would be impacted by the 

Memphis Regional IMF. Existing utilities along SR-57 

include electrical, telephone, cable, water, gas and sewer 

lines. A 12’’ water main and a 4” gas main are located 

parallel to SR-57 on the north side with an 8” sewer force 

main parallel to SR-57 on the south side. A water booster 

station along SR-57 would need to be moved. 

 

398 TDEC Division of Solid and Hazardous Waste Management, http://www.state.tn.us/environment/swm/solid_waste/. 

399 EPA 2005. Managing Your Environmental Responsibilities: A Planning Guide for Construction and Development, 

Office of Compliance, EPA/305-B-04-003, April 2005.
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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The project would fund utility relocations, including those 

described above. NSR would coordinate with appropriate 

officials to avoid or minimize damage or disruption of 

existing service during construction of the SR-57 overpass, 

lead tracks, and Memphis Regional IMF. Impacts are 

anticipated to be minimal and short term. TVA 

transmission lines that cross the proposed location of lead 

tracks would not require relocation. In the TVA 

transmission line corridor, another underground gas 

transmission line would need to be bridged by the lead 

tracks. 

The Developer would be responsible for funding the cost of 

utility connections to Industrial Road and the Memphis 

Regional IMF. 

3.19.5 Discovery of Unknown Archaeological Sites 

If archaeological materials are uncovered during 

construction, all construction work in the immediate area of 

the find will cease until appropriate clearances have been 

obtained. 

The SHPO Tennessee Division of Archaeology and the 

American Indian tribes with interests in the area would be 

immediately contacted so that representatives may have 

the opportunity to examine and evaluate the materials. 

Should earth fill be required for this project, the applicable 

TDOT borrow provisions would be followed. 

3.19.6 Erosion Control 

The project would disturb land that has a tendency to 

erode. The contractor would be required to employ BMP 

to minimize the impacts of point and non-point source 

discharge. An erosion control plan would be formulated in 

accordance with the TDOT’s Standard Specifications for 

Road and Bridge Construction and would include the 

following measures: 

 Temporary erosion-control devices, such as silt 

fences, check dams, sediment traps, sediment 

basins, burlap, jute matting, grading, seeding, and 

sodding, would be used to minimize erosion and 

sedimentation. 

 Minimize disturbed areas with vegetation being left 

undisturbed outside of the clearing limits. 

 Construct and stabilize fill slopes during the 

growing season. The majority of the fill slopes 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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would be constructed with a flatter (3:1) slope to 

reduce erosion potential. 

These measures would be implemented to the extent that 

they conform to provisions of the project permits. Due to 

the size of the project and the construction methods 

planned, the project must have more than 50 acres 

disturbed at one time. The project would be phased so 

that the entire 440 acres to be disturbed are not active at 

one time. Due to the acreage in each phase, the project 

would be required to obtain an Individual NPDES 

Construction Permit. As part of the individual permitting 

process, additional reviews of the site specific SWPPP 

would occur. When writing the individual permit, TDEC 

can place additional requirements and/or restriction on the 

construction activities, such as monitoring. The permit 

requirements and provisions will be followed to meet water 

quality standards. 

Construction of Build Alternative 1 would employ BMP to 

protect the recharge area and the quality of the water that 

may eventually enter the groundwater regime. Specifically, 

during construction, appropriate erosion and sediment 

controls such as basins, swales, silt fence, rock check 

dams, would be used to prevent suspended solids from 

entering surface waters. Moreover, fuel or lubricant spills 

that could potentially occur would trigger immediate 

response and cleanup via the contractor’s spill prevention 

control and countermeasure plan. 

3.19.7 Air Quality 

Construction operations could temporarily contribute to air 

emissions. The primary emissions include fugitive dust 

(i.e., particulate matter, either PM10 or PM2.5) resulting from 

the soils at the site becoming airborne and exhaust 

emissions from construction equipment. Construction 

equipment would comply with applicable requirements for 

control of MSAT. Additional tasks to complete the 

proposed project would lead to the short-term, temporary 

emissions of evaporative VOC emissions (e.g., asphalt 

paving and striping of roadways). 

Measures to control fugitive dust emissions during 

construction activities would include: 

 Site grading would promote good drainage and 

minimize the accumulation of mud on equipment 

tires that could be transferred to road surfaces, 

which could otherwise generate fugitive dust from 

wind erosion, traffic, or heavy equipment operation. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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 Ground surfaces would be stabilized as soon as 

practical to prevent wind erosion. 

 Those areas that would revert to maintained 

grounds would be reseeded as soon as practicable 

to reduce the potential for fugitive dust generation. 

 Clearing limits would be clearly marked to limit 

disturbance beyond what is required to construct 

the facility. 

 Bare ground in the construction area and on 

construction roads would be wetted if warranted to 

minimize fugitive dust from vehicle traffic during dry 

conditions. 

 Roadways used to access the site during 

construction would be wetted to minimize fugitive 

dust from traffic or heavy equipment operation. 

 Open or lightly traveled areas would either be 

paved, covered in hard packed aggregate, or 

vegetated to minimize fugitive dust emissions. 

 Construction roads and lay-down areas would be 

stabilized with suitable materials like stone dust to 

prevent wind erosion and dust generation by heavy 

equipment. 

 Stone-covered construction entrance and exit roads 

would be maintained to reduce movement of 

materials off-site on vehicle tires. 

 Cover or wet down truck loads of earth to prevent 

windblown dust. 

 Applicable air pollution control regulations with 

regard to open burning400, Hazardous Air 

Contaminants401, and the operation of fueled 

vehicles will be followed. 

 Where required, permits and operating certificates 

will be obtained. 

 Fuel burning construction equipment would be 

maintained in proper mechanical order to reduce 

emissions. 

 

400 TDEC regulations as specified in Chapter 1200-3-4. 

401 TDEC regulations as specified in Chapter 1200-3-11. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

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3.19.8 Noise 

Construction activities related to the proposed project are 

expected to temporarily increase noise levels within the 

project limits during the period of construction activities. 

The construction schedule is estimated to be 

approximately 2 years. Short-term noise levels from the 

proposed construction activities are estimated from the 

standard noise emission levels of construction equipment 

expected to be used (Table 3-21).402

Table 3-21: Standard Noise Emission Levels for Construction Equipment 

Construction 

Equipment 

Noise 

Level 

(dBA) 50’ 

from 

Source 

Construction Equipment 

Noise 

Level 

(dBA) 50’ 

from 

Source 

Air Compressor 81 Generator 81 

Asphalt Cutting Saw 90 Grader 85 

Backhoe 80 Jack Hammer 85 

Chain Saw 76 Loader 85 

Compaction Equipment 82 Locomotive (1000’ cars) 30 mph 80 

Concrete Mixer 85 Paving Machine 89 

Concrete Pump 82 Truck (3-5 axle) 88 

Dozer 85 Rubber-tired Roller 74 

Excavator/Shovel 82 Scraper 89 

Source: FTA 2006 

Perceived noise levels associated with a specific 

construction activity would depend on several factors, 

including: the type of activity; the types and number of 

equipment in use; the noise level generated by the various 

pieces of equipment; the duration of the activity; the 

distance between the activity and any noise-sensitive 

receptors; and shielding or absorption effects that might 

result from existing buildings, topography, or vegetation. 

Estimates of sound attenuation from potential construction 

activities for various distances from the proposed 

construction equipment are presented in Table 3-21.403

Based on noise emission levels at various distances 

presented in Table 3-22, anticipated construction 

equipment utilized for the proposed project could generate 

sporadic noise levels up to 70 dBA at the nearest 

 

402 Tennessee Environmental Procedures Manual, TDOT Environmental Division, April 2007. 

403 FTA 2006. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

Memphis Regional Intermodal Facility 3-202 

6/30/2010 

residences on Neville Road (800 feet from lead tracks), 

thereby creating temporary construction noise impacts to 

some area residents. 

Construction-related traffic is unlikely to have a substantial 

noise impact on the US Hwy 72 corridor during the 

proposed construction period. However, constructionrelated trucks and workers traveling on Industrial Road 

could produce traffic noise levels 5 to 8 dBA greater than 

the existing background noise levels at the closest 

residences (335-900 feet), thus creating temporary minor 

traffic noise increases for residences in the vicinity of 

Industrial Road. 

 Table 3-22: Predicted Attenuation of Potential Construction Activities 

Noise Levels (dBA) at 

50 feet from 

Construction Activities 

Distance 

from 

Construction 

Activity (feet) 

Range of 

Attenuated 

Noise Levels 

(dBA) 

80 

(Single typical 

equipment) 

100 74 

200 68 

400 62 

800 56 

1600 50 

90 

(Single loud equipment) 

100 84 

200 78 

400 72 

800 66 

1600 60 

95 

(Multiple equipment 

at 90 dBA each) 

100 89 

200 82 

400 76 

800 70 

1600 64 

 Source: FTA 2006 

NSR has also considered noise mitigation measures to 

minimize noise impacts during facility construction, 

including: 

 The proposed earthen berm noise barriers would 

be constructed as early in the construction 

process404 as is feasible to reduce construction 

 

404 Due to property/ownership issues, NSR would not be able to construct a berm on the west side of the lead tracks until 

after October 2010. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

Memphis Regional Intermodal Facility 3-203 

6/30/2010 

noise impacts to receivers expected to be 

benefited. 

 To the maximum extent practicable, the use of 

multiple pieces of construction equipment 

simultaneously at a concentrated area would be 

limited. Construction activities would be spread 

along the linear stretch of the proposed project 

area rather than being focused at a single point. 

 Restrict the use of the noisiest equipment (e.g., 

jackhammers, pile drivers, and other impact 

equipment) during evening and night-time hours, 

or the simultaneous use of multiple pieces of 

noisy equipment at a given location. 

 Construction equipment and vehicles used to 

implement this project would be properly 

maintained and equipped with applicable noise 

control elements (e.g., mufflers). Noise control 

devices, such as mufflers, should meet the 

manufacturers’ specifications for the equipment 

and/or vehicles on which they are used. All 

internal combustion engines shall be equipped 

with a muffler that meets the manufacturers’ 

specifications. 

 Illuminated and flashing traffic controls and 

construction signs located near residences shall 

use a quiet power source such as solar or 

batteries; internal combustion engines shall not 

be used for illuminated and flashing traffic 

controls and construction signs in areas of 

residential usage. 

 Construction traffic would be routed away from 

noise-sensitive areas, where feasible, and 

Industrial Road would be the primary point of 

entry. 

 Rail-based construction equipment would be 

operated at low speeds on the lead tracks during 

construction to minimize noise emissions. 

 A staging area would be established to store 

construction equipment during inactive hours to 

minimize daily movement of construction 

equipment off and on the site. 

 Construction equipment and vehicle engines 

would be shut off whenever possible. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

Memphis Regional Intermodal Facility 3-204 

6/30/2010 

 Concerns or complaints received from potentially 

affected residences would be addressed 

immediately and wherever possible corrective 

actions would be taken for issues that impose 

intrusive construction noise. 

3.19.9 Natural Resources 

Clearing and grading of the site for construction purposes 

would directly impact flora and fauna within the limits of 

disturbance for the facility and tracks. Vegetation within 

the facility footprint would be cleared and grubbed. 

Individual wildlife may be impacted during construction 

depending on the when construction occurs and the 

mobility of resident wildlife. Species occupying habitat 

within impoundments located within the facility footprint 

would be impacted (i.e., fish, turtles, aquatic invertebrates). 

More mobile animals (i.e., raccoons, birds) would likely 

vacate the area upon commencement of construction 

activities. 

Clearing and grading of the site for construction purposes 

would directly impact surface waters within the limits of 

disturbance for the facility and tracks. The Phase 1 EC 

Plans within the site specific SWPPP would include 

appropriate BMP to protect and divert surface waters 

during clearing operations. These BMP would include silt 

fence with backing and diversion channels with check dam. 

The Phase 1a and 2 EC Plans within the site specific 

SWPPP would include appropriate BMP to protect and 

divert surface waters during grading operations. These 

BMP include sediment basins, sediment traps, check 

dams, polymers, and rolled matting. The permanent and 

temporary impacts to streams and wetlands within the 

facility would be clearly defined and regulated as specified 

in the TDEC and USACE permitting process. 

Within the limits of disturbance for the facility and track, 

exposure of Memphis sands could occur during grading 

operations. The most likely area of exposure would be in 

cut sections of the operation yard along the eastern edge 

of the facility. If this occurs, stormwater would be directed 

away from the feature during grading. The area would be 

designed for additional processing during final grading. If 

the area is located beneath the proposed operational yard, 

a less permeable layer of compacted clayey soil would be 

placed over the exposed sand layer before final grading as 

identified in Section 3.12.6. If the area is located in an 

open space or ‘green space’ within the facility, the area 

would be graded so that stormwater is directed away from 

the feature. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

Memphis Regional Intermodal Facility 3-205 

6/30/2010 

3.20. Impacts Summary

Table 3-23 provides a summary of the potential impacts of 

Build Alternative 1. 

Table 3-23: Summary of Potential Impacts from Build Alternative 1 

IMPACT CATEGORY POTENTIAL IMPACTS 

Project Features 

Project Size Facility is approximately 7,000 feet long by 2,400 feet wide. 

Estimated Area Property is 650 acres; Facility is 380 acres; 233 acres of paved 

surface; 76 acres of track and 71 acres open (green space). 

Estimated Cost $129 million. 

Land Use 

Conversion from agricultural to industrial. Facility within 

Rossville UGB and zoned industrial. Industrial Road and 

surrounding ~1,500 acres being zoned commercial/industrial. 

Transportation 

Improved efficiency in transporting freight. Reduced truck traffic 

and associated congestion and emissions between eastern U.S. 

and Memphis. 

In 2032, US Hwy 72 will operate at LOS C including direct, 

indirect, and cumulative impacts. 

Farmland (prime/unique 

farmland/acres used) 

311 acres of prime and unique farmland/330 acres total 

farmland. 

Social and Economic 

Social/Community Cohesion No Adverse Effects. 

Community Services No Adverse Effects. 

Environmental Justice No Adverse Effects. 

Residential Relocations No Relocations. 

Business Displacements No Displacements. 

Economic 

Approximately 140 new full-time jobs plus temporary 

construction jobs. 

Economic impact of $2.7 billion by 2020 and growth of 6,186 new or 

benefited jobs. 

Air Quality No Adverse Effects; Minor increase in emissions of criteria 

pollutants and MSATs expected. 

Noise No Adverse Effects; 1 affected site with 3 residents. 

Cultural Resources 

Architectural/Historic No Adverse Effects. 

Archaeological Sites No Adverse Effects. 

Recreational Resources No Adverse Effects. 

Section 4(f) Resources No Section 4(f) Resources Used. 

Section 6(f) No Section 6(f) Funded Land On-site. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

Memphis Regional Intermodal Facility 3-206 

6/30/2010 

Table 3-23: Summary of Potential Impacts from Build Alternative 1 

IMPACT CATEGORY POTENTIAL IMPACTS 

Natural Resources 

Floodplains 

Zone A – 32 acres within project boundary; 1 acre of impact to 

be minimized in design. 

Zone AE – 4 acres within project boundary; 0 acre of impact. 

Ponds 

6 ponds totaling approximately 10 acres of impact; however, 3 

ponds (totaling 5.6 acres) are non-jurisdictional waters of the 

U.S. and would not require compensatory mitigation. Impacted 

lengths to jurisdictional ponds are included as stream impacts. 

Stream Impacts (Feet) 5,352 linear feet; all impacts will be mitigated. 

Wetlands (Wetland/Acres 

Impacted) 

9 wetlands / 7.31 acres potentially impacted; all impacts will be 

mitigated. 

Federally Threatened or 

Endangered Species None On-site. 

Aquifer/Groundwater 

No Adverse Effects. Impacts could occur from a spill of minor 

quantities of hazardous materials transported through or used 

by IMF. Stormwater system would allow positive control of 

discharges from the site and that would mimic pre-development 

hydrology. 

State-Listed Species No Adverse Effects. 

Invasive Species No Adverse Effects. 

Wild & Scenic Rivers None On-site. 

Visual No Adverse Effects. 

Pedestrian and Bicycle 

SR-57 overpass includes paved shoulders that will 

accommodate both pedestrians and bicyclists. Minor positive 

benefit. 

Energy 

Construction will require diesel for equipment. Operations will 

require diesel and electricity. However, 23.8 million gallons of 

fuel are estimated to be saved on an annual basis due to 

intermodal transportation mode. 

Hazardous Materials 

No Adverse Effects. No existing hazardous materials sites 

identified within footprint. Only minor quantities of hazardous 

materials transported through IMF. 

Permits 

(1) NPDES Construction General Permit (if needed). 

(2) NPDES Stormwater Individual Permit for Construction. 

(3) USACE Individual or Nationwide Permit for Impacts to 

Waters of the U.S. (including wetlands and aquatic resources). 

(4) ARAP (TDEC) for Construction and Removal of Minor Road 

Crossings. 

(5) ARAP (TDEC) - General Permit for Minor Alterations to 

Wetlands. 
3 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

Memphis Regional Intermodal Facility 3-207 

6/30/2010 

Blank Page 
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-1 

6/30/2010 

4 PUBLIC INVOLVEMENT AND 

One of the first steps in the NEPA process involved the 

and other stakeholders are given the opportunity to provide 

ent of 

environmental documentation. On July 31, 2009, TDOT 

of its intent to initiate the 

environmental document for this project under the NEPA 

 conducted several public 

meetings to gather local input regarding a proposed IMF in 

regarding the project and 

location. 

4.1.2 Coordination Packages 

 interested 

 included a 

nity 

ject, alternatives being 

dustrial Road onto US 

 that would be 

considered throughout the environmental documentation 

isted below. Agencies or organizations with 

a (C) and/or (P) by their names indicate whether the group 

(P) organization in the 

NEPA process for the project. Agencies without a 

t elect to participate in 

the NEPA process. 

INTERAGENCY COORDINATION 

The public, agencies, and other stakeholders have been 

given opportunities to provide input during project 

development in accordance with NEPA, CEQ, TDOT and 

FRA/FHWA regulations and guidance, as well as the TESA 

processes. This section describes the agency coordination 

process and public involvement activities that were 

conducted for this project. The key issues that have been 

identified through the coordination activities are described. 

4.1. Project Initiation and Coordination 

4.1.1 Project Initiation 

development of a plan to ensure that the public, agencies 

input into project development and developm

notified the FHWA in writing 

process. Prior to this, NSR

the area and to identify issues 

TDOT prepared a Coordination Package which was 

distributed to agencies, organizations and

parties on September 11, 2009. The package

transmittal letter, a project summary and a project vici

map. The project summary identified the preliminary 

purpose and need for the pro

considered, traffic counts from In

Hwy 72, and environmental concerns

process. 

Agencies and organizations receiving the coordination 

package are l

is a cooperating (C) or participating 

designation by their names did no
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-2 

6/30/2010 

Federal Agencies 

 U.S. Department of Transportation Federal Highway 

Administration (C) (P) 

 U.S. Army Corps of Engineers (USACE) (C) (P) 

 Water Resources Division, U.S. Department of the Interior 

Service (FWS) (P) 

ices (NRCS), U.S. 

Department of Agriculture (P) 

 Wetland Reserve Program Coordinator, U.S. Department 

VA) (P) 

otection Agency (EPA) Region 4 (P) 

ement Agency (FEMA) 

pliance, DOI 

ining, DOI 

ospheric Administration (NOAA), 

rt 

(TDEC) (P) 

 Tennessee Wildlife Resource Agency (TWRA) (P) 

 Tennessee Department of Agriculture (P) 

 Tennessee State Historic Preservation Office (SHPO) 

 Tennessee Department of Education 

 Mississippi State Historic Preservation Office (SHPO) 

(DOI) (P) 

 U.S. Fish and Wildlife 

 Natural Resources Conservation Serv

of Agriculture (USDA) (P) 

 Tennessee Valley Authority (T

 Environmental Pr

 Federal Emergency Manag

 Office of Environmental Policy and Com

 U.S. Geologic Survey (USGS), DOI 

 Office of Surface M

 National Oceanic and Atm

U.S. Department of Commerce (DOC) 

 Federal Aviation Administration (FAA), Memphis Airpo

District Office 

State Agencies 

 Mississippi Department of Transportation (C) (P) 

 Tennessee Department of Environment and Conservation 
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-3 

6/30/2010 

Local Agencie

 Departm conomic & nity Development, Lo

Planning Assistance Office, West Tennessee Region (P) 

 West Te e Regional Planning Office (RPO) (P) 

Regional Planning Office (RPO) Southwest Tennessee 

Develop istrict (P) 

RPO, M Area Assoc ments (P) 

 Memphis Metropolitan Planning Office (MPO), MemphisShelby partmen al Services (P) 

 Mayor o County (P

 Fayette lanning a pment Office (P) 

 Fayette County ber of Commerce (P) 







rgani

ci

th

ra

cy

 e

 t

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Section



 Mayor of Fa te County 

Alabama- sarte Tribal To

s

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nnesse

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emphis

County De

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 County P

 Commu

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t of Region

) 

nd Develo

cal 





 Cham

Mayor of Rossville (P) 

Mayor of Piperton (P) 

Mayor of Collierville (P) 

zations: 

Tennessee Trails Asso

Tennessee Chapter of 

Chickasaw Group, Sier

The Nature Conservan

Tennessee Wildlife Fed

Tennessee Environmen

Southeast Rivers and S

Fund 

 106 Consulting Partie

Mayor of City of Rossville

O









ation 

e Sierra Club 

 Club (Memph

ration 

al Council 

eams Projects

s: 

 

is Area) 

, World Wildlife

yet

 Quas wn 
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-4 

6/30/2010 

 The ic tio

 Cho w O 

 Eastern Band of Cherokee Indians 

 Eas S ri homa 

 Jena Band of Choctaw Indians 

 Kia n

 Mississip f C d s 







 Sha T

 cc al T

 ilo ians ia In

 e h Ba he ee

4.2. A

4.2.1 In cy rdina

The inv o ipat N A were 

sent to ab ede e, d L cies. 

Include inv n wa py th ation 

Package. None of the agencies provided comments to the 

actual C ion kage

Table m co s ei the 

agencies before starting the TESA Process as described in 

Section he ters ai re A. 

 Ch

cta

tern

legee 

coge

rch B

paw 

kasaw Na

Nation of 

hawnee T

Tribal Tow

pi Band o

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and of Cree

Tribe of Okla

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klahoma

be of Okla

 

hoctaw In

ation 

k Indians 

homa 

ian

Mus

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Qua

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 Agen

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 the 

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ribe 

o Trib

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 Coo

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 Pac

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 4.2

own 

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 an

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 Indians 

 process 

ocal agen

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 in Appendix
4 PUBLIC INVOLVEMENT AND INTERAGEN

Memphis Regional Intermodal Facility 6/30/2010 

 Table 4-1: Agency Comments

Agency Agency Comments ResponsDHS/FEMA Region IV (1) 

FEMA’s authority and participation here is limited to informing and advising the lead Federal funding agency (or authorized designee), for them to make their project-specific regulatory compliance evaluation and determinations under Presidential Executive Order 11988 (EO 11988) for floodplain management. EO 11988’s 8-step review process helps project decision makers to make more informed decisions about their project’s risks, options, costs, feasibilities, plans, designs, etc. EO 11988 requires documentation showing the project EO 11988 review was done, and the agency’s reasoning behind their project-specific EO 11988 determinations. The project EO 11988 eight-step review and documentation can be integrated into the project NEPA review process and review document. 

Acknowledge decline invitation website was used to collect floodplain within the Build Alterdiscusses the floodplain 

DHS/FEMA Region IV (2) 

AECOM, the design engineer, hRossville through Fisher and ARossville's consulting engineers potential floodplain issues. 

If the project may affect or be affected by a 100-year jurisdictional floodplain, then the lead Federal agency (or designee) would need to consult with all potentially affected communities’ Floodplain Administrators. For “critical facility” projects (e.g., police, fire, hazmat, public records, medical, nursing home, emergency shelter, water or wastewater treatment, etc.), that would be if the project may affect or be affected by the 500-year jurisdictional floodplain. 

DHS/FEMA Region IV (3) 

If applicable for the Memphis Regional IMF, that would require consultation with the Floodplain Administrators for Fayette County, and possibly for the City of Rossville, for their determinations. Both the County and the City participate in the National Flood Insurance Program (NFIP). Their Floodplain Administrators have floodplain management authority and responsibility for their jurisdictions. They may have different primary job titles. They may work in planning, zoning, development, public works, or another local government office. Search starting points: Fayette County: http://www.fayettetn.us/, City of Rossville: fttp://www.fayettetn.us/Towns&Cities/Rossville.htm. Each NFIP-participating community (county, municipal, or tribal) has a floodplain management ordinance modeled on FEMA’s regulations at 44 CFR Part 60.3. 1) Such ordinances require anyone proposing “development” within a specific jurisdiction to get a permit from that jurisdiction before starting any project physical work. 2) Such ordinances also require notification of adjacent communities and the State NFIP Coordinator before altering a watercourse (if applicable). 3) Affected communities’ floodplain management regulations and related flood insurance policy holders’ premiums are both tied to mapped flood risks. When physical environment alterations affect flood risks, the corresponding Flood Insurance Rate Maps (FIRMs) must be revised as outline in 44 CFR part 65 to keep flood risk maps current. 

Based on AECOM, the design eFisher and Arnold, Inc., the Town engineers and planners, the projno-rise condition upstream and Any floodwater increase would project footprint. 
4 PUBLIC INVOLVEMENT AND INTERAGEN

Memphis Regional Intermodal Facility 6/30/2010 

 Table 4-1: Agency Comments

Agency Agency Comments ResponsFAA No airports will be impacted. The proposed facility is beyond jurisdiction of FAA. Acknowledge. USGS USGS declines request to be an official participating agency. USGS is a source of scientific data and expertise concerning the natural resources of the project area. USGS sources have been used 

the Memphis Sand aquifer. 

NRCS 

Provide Farmland Rating Form and request to determine if any impacts to Wetland Reserve Program to Dept of Agricultural. Accept invitation to be participating agency. 

The Farmland Rating Form (Appto determine any impacts to Program were submitted to Ndiscusses farmland impacts and wetland impacts. 

TWRA 

Accept invitation to participate. Current concerns are potential environment impacts associated with potential stream, wetland, and floodplain impacts, and impacts to federally and state listed species that may occur due to the construction of this project. 

Acknowledge participation. The with TDOT. Impacts to natuavoided, minimized or mitigateAdditional explanation is in EA S

TN HistorCommission 

ical Project must follow requirements of Section 106 of the National Historic 

Preservation Act. TDOT published Section 106 lett

Town of Rossville, TN 

Accept invitation to participate. Concerned about project from a land use standpoint and its impact on our existing infrastructure. Request that Fisher & Arnold, Inc., who serves as the Town's consulting engineers and planners, be included in your distribution list for all of the various reviews, coordination meetings and field reviews as appropriate. 

AECOM, the design engineer, Arnold, Inc., the Town of Rossviand planners. Town of Rossmailings and reviews. 

EPA (1) 

1. NEPA Level of Analysis: EPA is concerned with TDOT FHWA pursuing an Environmental Assessment (EA) as opposed to an Environmental Impact Statement (EIS). The proposed project will have a large imprint of 570 acres and will increase traffic within the community. The project also has the potential to substantially impact water resources and increase air toxics. EPA recognizes the expeditious timeline of pursuing this project; however, environmental and socioeconomic impact analysis and public outreach should be proportional with the level of impacts. EPA recommends that TDOT/FHWA conduct a robust analysis of environmental and socioeconomic impacts (direct, indirect and cumulative), comprehensive mitigation planning and pursue an aggressive public outreachcampaign. EPA also recommends that TDOT/FHWA fully articulate the rationale for pursuing an EA versus an EIS in the NEPA document. 

TDOT and FRA in conjunction that an Environmental AssessmeNEPA document based upon a pimpact. EA Section 3 providenvironmental and socioeconomthe project will comply with protecting water, air, and other A robust direct, indirect, and cumaccordance with EPA, FRA , NEPA guidance has been pecomprehensive mitigation paproposed impacts, has been deinput procedures have been follofinal draft of the EA, FRA will mawhether the project will result warranting elevation to an Statement (EIS) and articulate its 
4 PUBLIC INVOLVEMENT AND INTERAGEN

Memphis Regional Intermodal Facility 6/30/2010 

 Table 4-1: Agency Comments

Agency Agency Comments ResponsEPA (2) 

2. Mobile Source Air Toxics: Evaluation of project of this magnitude should include consideration of the impacts of air toxics emissions on nearby population centers 

d be conducted using the 

approach described in EPA's Air Toxics Risk Assessment Reference Library (ATRA Library). We refer the sponsor of the project to the ATRA Library, Volume 1 and sensitive populations. The environmental assessment should include a detailed inventory of air toxics emissions (including diesel emissions) from both stationary and mobile sources that serve the facility, including the locomotives, switchers, tractors, and support equipment, etc. It should also include a screening level evaluation of the potential impacts of these emissions on neighboring populations at each of the locations being considered for the facility in order to allow an informed comparison of the level of acceptability of each of the locations being considered. The screening level evaluation coulSection 3.3.3 for further details (http://epa.gov/ttnlfera/risk atra main.html). The 

evaluation should include a description of the recent literature concerning the impact of air toxics emissions on near-roadway receptors, including sensitive receptors such as children and the elderly. The evaluation should also describe 

al Report on file with TDO

the methods that will be used to mitigate any unavoidable emissions and impacts. 

A Mobile Source Air Toxics completed pursuant to the FHUpdate on MSAT Analysis September 30, 2009. MSAT athe EA Section 3.6 and preseTechnic

NRCS (1) 

The Agency agree with the proposal's intent to select the least environmentally damaging alternative in the construction of the facility. Acknowledge. 

NRCS (2) 

Major streams, wetlands, and cultural resources should be avoided if at all possible. The fewest acres of these resources possible should be impacted. All negatively impacted areas should be fully mitigated. 

and it’s direct, indirect, and assessed in Section 3 along with of the site. TDOT has contactethe NEPA process. As an oupotentially impacted by the pronotice was published in both thand Fayette Co (TN) local newMemphis Commercial Appeal. 

EA Section 2 includes a discussi

NRCS (3) 

Any sites within the proposed facility subject to hazardous material transfer should be as far away from any possible receiving water and fully buffered against any possible spills. 

No hazardous material transfeAlternative 1 except in very radefective trailer or container mthe contents moved to anotheNSR will fuel diesel locomotives areas will be located away from rControl plans will be develope
4 PUBLIC INVOLVEMENT AND INTERAGEN

Memphis Regional Intermodal Facility 6/30/2010 

 Table 4-1: Agency Comments

Agency Agency Comments ResponsTown of Collierville (1) 

Environmental Concerns: 

The impacts to groundwater, wildlife habitat, air quality, 

and wetlands are a regional concern, and do not recognize govern

ment 

boundaries. The State of 

Tennessee is blessed with many natural resources, and 

has wisely adopted many regulations to ensure their protection and conservation. 

Impacts to natural environment wor mitigated during project desigis in EA Section 3.12. 

Town of Collierville (2) 

St e th

d ro d

t that e

m al priv f

Equitable Application of Railway to meet or exceethis use to hold itself to citizens, which are not elaw. 

andards: We implor

 Tennessee's tough 

he same restrictions

powered with speci

e th

envi

State and Norfolk Sou

nmental regulations, an

apply to our private s

ileges and exemptions 

ern 

 for 

ctor 

rom 

NSR will be required to follow NPDES Construction Permit requ

Town of Collierville (3) 

Threat of Hazardous Material Spills: Of particular concern to Collierville is that we do not fully understand the truck movements or rail traffic anticipated by this new location, and thusly cannot ascertain and plan for the risk of any adverse environmental impacts due to accidental spills of toxic loads being carried by rail or on the road, and the resulting impacts to our role as a groundwater recharge for the region, and the quality of our streams and drainage conveyances. 

EA Section 3.16 addresses haz1-1 pictorially depict the flow of ftruck to train and back to short haoperations, hazardous freight in tis not transferred to another contunless there is a mechanical protrailer; this is an extremely rare explanation of the IMF opeAlternative is in EA Sections projected, the IMF trains will nleaving the facility between 6 p.menter and exit the IMF 24 hours a 

Town of Collierville (4) 

Noise and Air Quality: Similarly, understanding noise and air quality impacts for the anticipated truck routes is imperative. 

Qualit echnical Report and No

file with TDOT. The noise study impacts due to truck traffic on SRoutside of the study area accommodate truck traffic like thfacility. Presumably noise impa385 would have been addressed route. The Air Quality Technical Reporwere completed in support of the in the EA Sections 3.7 and 3.

y T

Town of Collierville (5) 

Land Use Impacts (Gateway to Collierville, Shelby County, State of Tennessee) In April 2009, Collierville adopted a Small Area Plan for the I-269 (see attached) area that anticipated upscale and walkable office, retail, light manufacturing uses, and could support a population of approximately 8,000 additional residents. Of particular concern would be the viability of this adopted vision for this new gateway given the prospect of high truck traffic. 

Build Alternative 1 is not within tSmall Area Plan for I-269. MRossville UGB, the EA Section 3industrial, EA Section 3, Figure 3
4 PUBLIC INVOLVEMENT AND INTERAGEN

Memphis Regional Intermodal Facility 6/30/2010 

 Table 4-1: Agency Comments

Agency Agency C

omments Respon

s

TowColli(6) 

a ear 

e iate 

tion 

e are 

a us 

i eds 

m

o

lu

a

D

e 

e

l 

5

h

vi

n of 

erville 

Traffic Concerns: Since the decision hHighway 72 (US 72), Collierville and our nand comprehensive help from the State

(TDOT) to understand and help prevent sitems that we have considered locally to to know where to prioritize our efforts without knowing the full impact of the inter

s been made to put the facility n

ighboring communities need immed

and the Department of Transporta

rious traffic problems. The following

ddress this issue, but it is difficult for

n pursuing these transportation ne

odal facility. 

TDOT is sponsoring a study broader highway network, incother improvement projects alrethe Traffic Study on file with Tnot change the Level of ServicMarshall County, which is wherand exit the facility. AdditionaSection 3.3 and 3.18.2. SR-38

scope of this EA. TDOT will scNSR and the Town of CollierStudy. 

MD(1) 

ti WA 

h MF) OT Accept invitation to be a Cooperating/Par in the NEPA documentation for the Memp

in Fayette County, Tennessee. 

cipating Agency with TOOT and FH

is Regional Intermodal Facility (MRI Acknowledge 

MDOT (2) 

d ippi 

t tive 

r

 

t

a

n

Created Analysis of Projected TVicinity of the Intersection of USIndustrial Road to address direccumulative impacts in existing trintersection of US Hwy 72 and I

Concern with the impacts to US 72 anresulting from the MRIMF and andevelopments. 

 the surrounding areas in Mississ

icipated secondary and cumula
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-10 

6/30/2010 

4.2.2 Section 106 Coordination 

This project has been coordinated with parties pursuant to 

regulations defining Section 106 of the NHPA.405 A 

description of that coordination is also included in Chapter 

3, but is briefly described below. Early coordination letters 

were sent to Native American tribes, local governments 

(Rossville and Fayette County mayors) and the Tennessee 

SHPO informing them of the project, and as applicable, 

inviting them to serve as Section 106 Consulting Parties for 

 objections to the project, they would 

nd archaeological reports 

SA Process 

Streamlining Agreement 

each signatory 

, 

 

this project. No responses were received from the City 

and County mayors. No tribes provided responses to the 

TDOT’s coordination letter. The FRA sent out a second 

letter to potentially interested tribes. Though no tribes 

have yet expressed

be notified immediately if any human remains or artifacts 

falling under the National Native American Graves 

Protection and Repatriation Act (NAGPRA)406 are 

discovered during construction. In the construction plans, 

the contractor will be instructed to stop work and to inform 

NSR and the State Archaeologist of any suspected finds. 

Both the architectural/historical a

prepared pursuant to Section 106 have been coordinated 

with the Tennessee SHPO. In letters dated January 28, 

2010 and February 9, 2010, the Tennessee SHPO 

concurred with the findings of the reports that the project 

would not affect properties under Section 106. Copies of 

these letters are in Appendix B. 

4.2.3 TE

The Tennessee Environmental 

(TESA) is a cooperative agreement between the 

Tennessee Department of Transportation; the Federal 

Highway Administration; various Resource and Regulatory 

Agencies, and the Metropolitan Planning Organizations 

within the State of Tennessee. 

TESA sets forth the responsibilities of the signatory 

agencies relative to the priority review of transportation 

projects. The Agreement is entered into by 

agency with the goal of achieving timely planning

development, design and implementation of adequate, 

safe and economical transportation improvements while 

also assuring such planning, development, design and 

implementation is sensitive to the protection and 

improvement of the resources for which each agency is 

responsible under Federal or State statute and regulation. 

 

405 36 C.F.R. 800. 

406 25 U.S. C. 3001 et seq. 
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-11 

6/30/2010 

Ultimately, this streamlined environmental process is 

intended to achieve the timely and efficient identification, 

evaluation and resolution of environmental and regulatory 

issues. The Agreement establishes "one decision‐making 

process" to identify and address agency issues at four (4) 

key points, termed concurrence points, during the planning 

t

TDOT combined the TESA Concurrence Point #1 (Purpose 

A

I is decision 

was based on the fact that NSR provided public 

selection

F

location. 

M

years. 

T

Alternatives package was distributed to all TESAparticipating agencies with the lead agencies requesting 

P

IMF. 

c

d

agency correspondence and a summary of comments 

received from the reviewing agencies are included in the 

reliminary EA document. 

e Point 

ther applicable 

quately on 

and National Environmental Policy Act process for 

ransportation projects. 

& Need) with TESA Concurrence Point #2 (Proposed 

ctions & Alternatives) for the Memphis Regional 

ntermodal Facility (Memphis Regional IMF). Th

participation opportunities in the early process of site 

 (including evaluation of three other locations in 

ayette County), before focusing on the Build Alternative 1 

 The size and complexity of construction of the 

emphis Regional IMF will require approximately two 

he combined Purpose & Need and Proposed Actions & 

formal concurrence on the project’s Purpose & Need and 

roposed Actions & Alternatives for the Memphis Regional 

 All participating TESA Agencies concurred with the 

ombined Need & Purpose and Alternative sections of the 

raft EA (Concurrence Point #1 and Point #2). A copy of 

Summary of CP #1 and #2 document, dated January 2010. 

Concurrence Point #3 is the p

Based on the outputs from Concurrence Points #1 and #2 

and the subsequent detailed investigation of alternatives 

and analysis of impacts, the output of Concurrenc

#3 should include concurrence from the participating 

agencies on the adequacy of the preliminary EA. The 

agencies have asked to specify whether additional 

information is needed to fulfill o

environmental reviews or consultation requirements. In 

addition, the participating agencies have specified any 

additional information needed to comment ade

the EA analysis of site-specific effects associated with the 

granting or approving by the agency of necessary permits, 

licenses, or entitlements. A copy of agency 

correspondence and a summary of comments received 

from the reviewing agencies are included in the Summary 

of CP #3 document, dated May 2010. 
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-12 

6/30/2010 

The preliminary EA package was distributed to all TESAparticipating agencies with the lead agencies requesting 

formal concurrence on the project’s Draft EA for the 

Memphis Regional IMF. All participating TESA Agencies 

concurred with the Draft EA (Concurrence Point #3). A 

copy of agency correspondence and a summary of 

c ce wing re 

in S u

2010. 

Based on FRA’s approval of the EA for public review, a 

public hearing will be conducted in accordance with NEPA 

requirements and requirements in the project’s Public 

Involv nt Plan. 

Conc ce Point # preferred alternative and 

preliminary mitigation sed on the output of 

Concurrence Point #3 h TDOT and FRA’s 

consideration of any issues, concerns, and/or opportunities 

identi during the ings and comment period 

for the EA, TDOT will prepare a Preferred Alternative and 

Preliminary Mitigation Package. 

The output of Concurrence Point #4 shou nclude

concurrence fr agencie n the

selection of the preferred alternative and preliminary 

mitigation. Based on the output from Concurrence Point 

#4, TDOT will finalize their selection of a preferred 

alternative and prepare a final document for submittal to 

FRA.

4.3. Public Involvement 

A public information me eld in Piperton, Fayette 

County, Tennessee, tober 22, 200 t the 

C

S e purpose of the 

m he Memphis 

Regional In ection 4.1, 

b ss, NSR conducted 

s input from the local 

community regarding the proposed project. 

TDOT ran the meeting per their guidelines. Upon signing 

in, attendees received a handout providing a summary of 

the proposed project. Formal presentations were made 

and comments were solicited during the question-andanswer period following the presentation. Staff was 

available at displays to answer questions before and after 

the presentation. 

omments re

cluded in the

ived from the revie

ummary of CP #3 doc

agencies a

ment, dated March 

eme

urren 4 is the 

. Ba

, along wit

fied public hear

ld i

om the participating s o

 

eting was h

on Oc 9, a

ommunity Room at The Bank of Fayette County at 1265 

tate Route 57 in the project area. Th

eeting was to solicit public input on t

termodal project. As noted in S

efore the initiation of the TESA proce

everal public meeting to obtain
4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-13 

6/30/2010 

Meeting attendees were encouraged to record their 

comments with the court reporter present at the meeting, 

and/or to provide written comments using a comment from 

either at ing in 21 ollowing e 

meeting. 

 The public i al me atte

by approxim itize 7 T

M N ntat

 F e ceive the p 

m w siss from

S Pip

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m ind reco

c urt Th 

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P Me enne

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the information provided whe ned in

( om i an 

w

 Eighteen comment c other 

comments w iv 21 day 

comment period after t ing (ten 

fro iss en ee plus 

one from the Wolf River Airport and GWI, 

re ly)

 mm by 

e by 

itize vill

abl 2 a to mm 

nto era ries

The official eco le at 

TDOT Env l eade 

Stre Na n

Table 4-3 i pu 

comments r n

A public h 

following FRA and TDOT’s approval of this document for 

cir The public hearing will be advertised in

Fayette Coun nness rshall C Missi

and Memphis n papers Draft E e avail

for the public to review at Collierville nnessee 

the meet

DOT, and

our comm

eeting (t

ierra Club, a

welve indiv

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eting is availab

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onsolidation of 

 response. 

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4 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION 

Memphis Regional Intermodal Facility 4-14 

6/30/2010 

Byhalia Mississippi Public Libraries, Rossville City Hall, 

and MDO district of in a the H y

Springs pr c ete by M T

Table 4- nt ped b

T’s fice

oje t office to be d

2: Public Comme

 B tesville and

rmined

s Grou

oll 

DO . 

y EA Topics 

Applicable 

EA Section Comment Category 

Number of 

Comments Made 

1 Funding 8 

1 ion Operat s 7 

2 ve Alternati s * 40 

3.1 Land use 16 

3.2 nd Farmla 4 

3.3 ic Traff 53 

3.4 al Soci 8 

3.6 my Econo 12 

3.7 Air 12 

3.8 e Nois 18 

3.12 Natural Resources ** 41 

3.13 Soils 1 

3.15 Visual 9 

3.16 Hazardous Material 5 

NA Property Value 12 

NA Wind 1 

- Other 25 

Note: Categ ber of c

* Section 2.2 v

 Section 2.

 Section 2. s

 

** Section 3 1

 Section 3 o

ories within the tabl

: No-Build Alternati

3: Build Alternative 1

3.1: Memphis Altern

.12:7: Stormwater - 

.12.6: Aquifer - 13 c

e with larger num

e - 7 comments

 - 5 comments

atives - 13 comment

6 comments 

mments 

omments were
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

1 

Operation 

The purpose and need of the IMF is addressed in 

The primary existence of this development by Norfolk Southern is their greenbelt project, which is to get trucks as fast as possible off this intermodal to Pennsylvania. Isn't that pretty much the project description? 

Memphis Regional IMF would flatten the increase haul trucks from the highway system by transferrtrailers to the IMF trains. The project would imprefficiencies regionally and nationally. 

1 

Operation - 

Trains 

I do not see a problem with lines backing up into a main artery. Depending if single stack or double stack, they would carry anywhere from 130 containers to 260 containers. That's how many trucks there are in reality pulling off the road. What time of day would the trains be coming off the spur? 

IMF operations are explained in the EA Section 1would be transported on an IMF train. Approximtrains terminating at the facility and 4 new eastboat the facility are expected. Trains are expected IMF between 6 p.m. and 6 a.m. (subject to chan

 1 and 2 

Operation - 

Trucks 

Unclear on how trucks would exit facility and head north to PA. Where are the trucks going? Is SR-385 going to continue or be

hich is to get trucks as fast as possible off this 

connected at Macon Road? Would SR- 385 connect to I-40? What's short haul truck and how they transfer load? The primary existence of this development by Norfolk Southern is their 

greenbelt project, wintermodal to Pennsylvania. Isn't that pretty much the project description? 

IMF operations and highway proximity is explaineand 2. As shown in Figure 1-1 of the EA, trucks freight haulage while trains are used for long-hauwith I-40. Information on SR-385 is shown in Fig

1 

Operations - 

Intermodal 

Intermodal is the most efficient form of transportation. The purpose and need of the IMF is addressed in 

including the effectiveness of the IMF form of tra

2.1 

Alternative – 

in other 

locations 

Several other areas were recommended for review for the facility's location including: (a) TDOT building another bridge over Mississippi River with the IMF being located in Arkansas, (b) Less-developed area such as Corinth, Mississippi, (c) further east in a less developed area between Rossville and Moscow or between Moscow and LaGrange, or (d) closer to I-40. 

 is addressed in 

alternative selection criteria are addressed in EA other suggested locations (not evaluated as part the project’s purpose and need. The suggested meet the site screening criteria defined in Section location and sites closer to I-40 do not fit the neecustomer base which is moving south and east oMoscow, and LaGrange are too far east to easily base. As discussed in the EA, several locations Moscow were considered but eliminated from furThe Rossville area fits well with the warehousing 1-9), proximity to highway infrastructure, proximit(Figure 2-2), and locations with sufficient space fThe purpose and need of the IMF
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

2.2 

Alternative – 

No-Build 

Prefer the No-Build Alternative, meaning the proposed facility would not be constructed and existing NSR facilities would continue to operate at current capacity. It is the best for this community. There is absolutely NO public need for a new facility to be built in Fayette County. Existing facilities are not at capacity and rail traffic is decreasing with drop in international trade. This facility would be better suited for an existing industrial zone. 

The purpose and need is addressed in EA Sectioselection criteria are addressed in EA Section 2. alternative does not meet the need and purpose commenter has provided no justification for the ppublic need for additional freight transportation to future demand. NSR's existing IMF in Forrest Paabove its original design capacity and is currently methodologies to handle the volume of freight mo

2.3 

Alternative - 

Build 

The Build Alternative is very non-intrusive and in a vital crossroads for regional traffic. Proposed Location is an excellent location. The negative comments are a minority opinion. Build Alternative is the best of the several proposed options. Piperton Hills is a better option than the Wyndyke site. It addresses the critical issue of keeping the added truck traffic off of SR-57. Is the build alternative necessary? 

The purpose and need is addressed in EA Sectioevaluation criteria are addressed in EA Section 2best meets the defined criteria and is the only buforward into the environmental assessment. 

2.3 

Traffic - 

Access 

Would the access road to the site be a 2 or 4 lane road? Like access road to US Hwy 72. Excellent idea to keep truck traffic off of SR-57. Be sure that truck induction does not impede traffic. The only road access to it is a private, narrow, one-land gravel farm road. What kind of off-ramp is proposed and who would pay for it? 

Industrial road would be a paved two-lane road. and the traffic and potential impacts from the Indaddressed in the EA Sections 2.3, 3.3, and 3.18. enter and exit the IMF from Industrial Road onto 57. Industrial Road will be a Developer built, twothat connects the facility and other zoned industrThe private Developer would be responsible for cconnection from Industrial Road to US Hwy 72 as four-lane divided highway. 

2.3.1 

Alternative – 

in East 

Rossville 

Build the new Memphis Regional Intermodal Facility (IMF) on the original project site located on the north side of Highway 57 east of Rossville adjacent to the Norfolk Southern Railway Mainline track. 

Alternative selection is addressed in EA Section not meet the evaluation criteria. It is less intrusivcompared to Build Alternative 1, but was deemed environmental and cultural concerns and traffic im
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

2.3.1 

Alternative – 

in Memphis 

The best alternative would be to build the IMF in Memphis, where there is existing infrastructure and warehouses. Its closer to FedEx and the international airport; not in the rural and residential areas of Fayette County. There are idle or underutilized warehouse spaces in Memphis. Frank C Pidgeon Industrial Park is looking for a rail company to move in; sharing of rail lines among competing rail companies could be worked out. NSR is using taxpayer money and cheaper rural land to position themselves for an advantage over the other 4 competing rail companies operating in Shelby County. This facility would be better suited for an existing industrial zone. Since FEDEX is the major employer, how would you relate and coordinate with them? 

The purpose and need is addressed in EA Sectioselection criteria are addressed in EA Section 2. alternatives do not meet the evaluation criteria esthe facility. Suitable IMF locations are limited witbased on the defined evaluation criteria. FedEx customers expected to utilize the Memphis Regiowarehouses are already moving southeast of MeFigure 1-9; therefore, Build Alternative 1 better fitlong-term usage of the facility. The Memphis alteoperationally and economically unfeasible as anathe EA. 

2.5 

Alternative –

SubAlternatives 

Project is in preliminary design phase. Due to limdesign (grade and curve restrictions), options are facility including the length and location of the lea

Why couldn't it be just a little bit further east rather than so close to our neighborhood (Neville Rd). Why sandwich the IMF between 2 roads? IMF needs to be more in the middle between US 72 and SR-57. 

2.5 

Overpass - 

Neville Road 

It appears that the overpass is going to end right at Neville Road, can it be shifted away from Neville Road. Suggests: 1. Install a traffic light with triggers allowing Neville Rd traffic to enter SR-57 without unnecessarily delaying SR-57 traffic. 2. Provide left turn lanes for east and westbound traffic on SR-57 turning onto Neville Rd. 3. Move the SR-57 overpass as far East as possible. 4. Reduce the speed limit through the intersection. 

Project is in preliminary design phase. Due to limdesign (grade and curve restrictions) options are facility including the lead tracks. Traffic study at Road intersection was conducted, which showed light nor turn-lane was warranted.

407

407 In accordance with TDOT and FHWA guidance. 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.1 

Land Use 

NSR should only be allowed to build on land zoned for 

housing plants and existing residential property) be 

provided? The 4-mile access road through 3,000 acres of green 

ni

 types match the a

commercial/industrial. IMF is inappropriate at the proposed location, it's a rural/residential area more suitable to upscale "farmette" development; not a heavy industrial. Concern about destructive urban sprawl. Would adequate buffers (between warespace is too much land consumption for a facility that only needs approximately 400 acres. NSR said impacts from the access road would not be part of the EA. With the proposed “Chickasaw Trails Industrial Park”, the area would essentially be transformed to highly industrialized. The drastic, permanent negative eyesore created by a venture of this magnitude. You can never undo the harm this commercialization would create. 

The land use and potential impacts are addresse3.1 and 3.18, and in the Air, Ecology and Noise Tfile with TDOT. Fayette County's urban growth pand zo ng regulations, and Marshall County's zodetermine whether the activityproject site is zoned industrial, Figure 3-2. The Iacres with 380 acres to be developed, including 2parking. The project will obtain and comply with Marshall County zoning does not require buffers and commercial or industrial properties. The firsChickasaw Trails Industrial Park previously open

3.1 

Land Use 

Input 

Copies of Mid-South Horse Review from May and Sept. The articles were reviewed as part of preparing t

3.2 

Farmland 

The IMF would have a great impact on farmland. Practically all the land in this area is agricultural – pastureland, woodlands, and farmland. Several area farm owners and residents said their economic livelihood would be negatively impacted. Putting such a facility on prime, pristine farmland in the midst of a bedroom community is totally inappropriate land use. 

The farmland and potential impacts are addresse3.2. Based on coordination with NRCS, the facilsubstantial or significant. The site would remove less than 0.2% of the available farmland in FayetFayette County alone, 227,434 acres were desig(approximately 50% of Fayette County’s 451,839 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.3 

Traffic 

IMF would create bad traffic. IMF would create enormous road hazards and safety concerns for individuals traveling area highways this dangerous stretch of highway. N Lenderman Rd outlets to US Hwy 72 within approximately 14 mile from where 1600 plus trucks would enter and leave the 2-lane section of US Hwy 72 per day. Concerned about inadequate access for trucks coming from IMF to US Hwy 72 and substantial increase in traffic to SR-385 interchange. I do not feel traffic has been adequately addressed and US Hwy 72 would become another US Hwy 78. What type of changes would occur in our road structures (traffic lights) with new access road? SR-57 is a bottleneck coming into Collierville from Fayette Co.; The IMF would worsen traffic flow and increase commute times. What are the planned road improvements/expansion to accommodate such a large facility and additional semi trailer? The IMF would make access to Collierville from Marshall County a nightmare. 

Traffic and potential impacts from the facility opeare addressed in the EA Section 3.3, 3.18.1 and Traffic Study on file with TDOT, the IMF traffic doLevel of Service (LOS) on US Hwy 72. Impacts tprocessing vehicles into the IMF would be minimand operations. The IMF is not expected to direcSR-57, due to lack of direct access. TDOT is spotraffic impacts on the broader highway network, iassessment of other improvement projects alread

3.4 

Social 

er changed – 

oided, minimized or mitiga

Evaluate the socioeconomic impact. People, who live near it, are concerned about their lifestyle, their quality of life, etc. Numerous foreseeable problems (decreased residential development and property taxes; negative social impacts on community) are expected to impact area residences' lifestyles, livelihoods, and quality of life. Other rail yards in and around Memphis are filth 

pits, unsightly, crime-ridden. Our life would be forevin a negative way. I see no immediate impact to myself or my property, but our lives would be totally changed. 

The potential social and land use impacts are adSections 3.1, 3.4 and 3.18 and in the Air, EcologReports on file with TDOT. As noted in the EA, texpected to have significant social or land use imobtain and comply with applicable permits. Impaenvironment will be avdesign. The project site is zoned industrial, Figu

3.4 

SocialEmergency 

Services 

Fayette County does not have the financial resources needed to support this facility. The police, fire and emergency respondents as well as the general upkeep of roads associated with heavy truck traffic would take more taxpayer money then Fayette County can afford. NSR did not help taxpayers with the additional support needed. With all the growth, traffic etc., more police and fire departments would be needed in the area. The roads would need a better sub-base to hold all the additional truck traffic. 

The social and local community and potential impthe EA Sections 3.4 and 3.18. Additional expendpolice, fire and emergency respondents could ocincreases as a result of the IMF. However, potendevelopment in the area could increase the tax bpotential increase in emergency response personmaintenance, if required. Fayette County, Tenneemergency services, while Marshall County, Misslocal improvements to area roadways. Industrial Developer maintained. NSR pays taxes on its opTennessee as determined by the State Comptrol
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.6 

Economic 

Impacts 

The economic benefits from the IMF are in the E

The Build Alternative would stimulate the economy and raise local property values, but it would severely impact on my neighbors who bought and built anticipating life in an upscale residential area. 

3.18.4. Based on a regional study, the Memphis contribute to a cumulative economic impact of $2to employment growth of 6,186 new or benefited period.

408

 Based on the EA, the IMF would not s

nearby residential neighborhoods. 

3.6 

Economic - 

Taxpayers 

The application for tens of millions of federal taxpayer money for this project is absurd. The citizens would not get anywhere near the return of benefit for their taxpayer money. It would not take that many trucks off the road and would not create many jobs. The IMF is NOT in the best economic interests of the state, or community of residents who would have to pay increased taxes for public financing of this private, for-profit venture. Using a Cost of Community Services Analysis (COSA), is the project viable? 

The economic and potential impacts of the IMF aSections 3.6 and 3.18. Based on the criteria estaconstruction of the Memphis Regional IMF potenfederal funding assistance. The final public benecalculation will be made by the DOT. The cost oland is similar to that for other commercial and incost of service analytical data and a trust analyseindustrial land uses have lower cost of service thindustrial.

409

 COSA is a tool utilized by land use 

applying revenue and budget data and projection

3.7 

Air 

Area's air quality is very good with virtually no sources of air pollution. The expected 1668 semi-trucks per day would generate considerable toxic air pollution and fumes, including CO2, NOx, CO and particulate matter, which is so detrimental to human lungs, and causes even greater harm to horses’ lungs. The facility would contaminate the air with toxic chemicals; What would the facility do to air quality in Rossville? Would locomotives be idling all the time (auxiliary power units for locomotives)? The extensive paved area would contribute locally to planetary greenhouse warming. I would like NSR to perform air quality monitoring. 

Air quality and potential impacts are addressed in 3.18, and 3.19. EPA has established emissions CO, and particulate matter and the facility is desiapplicable emissions standards. The Air Quality file with TDOT presents the results of the analysiemissions and air quality impacts from facility conoperation. The report indicates the facility would impact on air quality nor require mitigation. 

408 Insight May 2009.409 American Farmland Trust, Farmland Information Center, Fact Sheet Cost of Community Services Study, August 2006. 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.8 

Noise 

The IMF would significantly increase noise and disrupt peaceful lifestyles. Other rail yards in and around Memphis are noise polluters. I do not feel enough studies have been conducted on the immediate and long term effects from this project in regards to noise. I would like to see actual noise monitoring done at existing facilities and then that information is used to interpret what's going to happen at our facility. The actual intermodal was going to be set down 28', which would kind of have its own berm or whatever you want to call it, where it would minimize noise, is that still the way it’s going to be? The IMF would become a loud and industrial place as the trucks and rail cars move in and out of the area. Noise destroys people’s relationships, contributes to loss of mental relaxation, can contribute to conflict, and reduces the quality of life in a community. The peaceful serenity that we now enjoy would no longer exist. 

Noise and potential impacts from the facility consare addressed in EA Sections 3.8, 3.18, and 3.19Report on file with TDOT indicates that the potenfacility potentially affect three residences. The noin part on results of actual noise monitoring condin Austell, Georgia. Although not required by the Memphis Regional IMF design includes berms aof the facility and between a section of the lead tto reduce noise impacts. 

3.8 

Noise on 

Nev oad 

Noise and potential impacts from the facility consare addressed in EA Sections 3.8, 3.18, and 3.19

ille R

How close is the noise berm (Neville)? We would have the noise to consider from the trains entering the facility (Neville Road). My concern is the noise factor. And if there's going to be any kind of an earthen barrier or anything, because the only thing between us and the railroad, which is about 500 feet from the back of my house. Noise pollution needs to be minimized at the lead track as well as in the IMF by berms and/or other means. 

Report on file with TDOT indicates that the potenfacility potentially affect three residences. Althounoise analysis, the preliminary design includes aancillary noise mitigation benefits between a secand Neville Road. 

3. 12 

Habitat 

The IMF would damage vast wildlife habitat, naturalized and rare plants, mature forest, and native hardwood forests. Paving approximately 386 acres of what is currently pasture and wood would be enormous ecological impacts by transforming “natural” landscape and drastic changing wildlife habitat. I do not feel enough studies have been conducted on the immediate and longterm effects from this project in regards to wildlife. The site would disrupt migration patterns of birds and destroy the current ecological system, which supports a vast array of wildlife. I manage my farm as "greenly" as possible, 

The natural resources and potential impacts incluaddressed in the EA Sections 3.12, 3.18, and 3.1Report on file with TDOT. The IMF property is 65acres developed, which constitutes a very small currently in forest or agriculture within Fayette Coobtain and comply with applicable permits which resources. A threatened and endangered speciefound no significant impacts. Impacts to natural avoided, minimized or mitigated during project de
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.12.6 Aquifer 

GWI, Univ of Memphis, along with local residents expressed concerns about the facility being located within the Memphis Sand Aquifer recharge area. Safety of the water quality within the aquifer is important. Land use changes would affect both the quantity and the quality of the water, potentially affecting the water table. Pollutants from the rail system and trucks would drain into the groundwater affecting our water supply. IMF is an industrial operation that would have unavoidable leakage and spills even with precautions. What long-term unintentional affects with the facility have on the aquifer? There has been no study onhow this unavoidable pollution would affect the water supply. 

Memphis Sand and potential impacts are addres3.12 and 3.18. Since all the alternatives were wiAquifer footprint, it was not a distinguishing factolocations. Information from GWI (including phonmeeting with Dr. Anderson) was used in preparipost-hydrology will not change significantly due tconstruction would include roller-compacted concessentially cap possible exposures of the Memphrunoff would be routed through “dry” detention ba

3.12 .7 

Stormwater 

The IMF will be drastic changes to stormwater by impacting the Wolf River watershed, Memphis Sand Aquifer, and private water wells by: paving within recharge/outcrop areas, increasing volume and intensity of rainfall runoff, and creating polluted runoff. It will impact both the quantity and quality of our regional drinking water source. The IMF will pave 500 acres of storm retention area and release runoff directly into two streams that converge on north end of Wolf River Airport, causing serious flooding and safety hazards. Do not make any final decisions regarding the project until all of the environmental and hydrology studies have been review and impacts assessed. The IMF will add toxic runoff into our streams and aquifer from the oil and diesel that trucks and trains consume. Groundwater safety should be studies on the immediate and long term effects from this project. Stormwater from the property should be impounded and treated before it's released into tributaries; not just retention. Actual water monitors should occur. What will NSR do to make sure and keep the water as clean as possible? 

Stormwater and potential impacts are addressed 3.18, and 3.18. Hazardous materials and potentaddressed in the EA Sections 3.16 and 3.18. Preincluding stormwater discharge will not change sproject. Potential floodplain impacts will be avoidmitigated. The project footprint is extremely smapotential recharge area of the Memphis Sand Aqwater quantity or quality in the aquifer is expecteobtain and comply with applicable NPDES permidischarges meet water quality standards. Approused to prevent erosion, control sediment movemdisturbed soil. Impacts from post-construction hythe Zone A floodplain will be avoided, minimizedproject design. 

3.13 

Geotech 

studied so that you don't have stabilization 

issues or fill issues (as to the quality) we don't want coal ash from Kingston, Tennessee, spill in the fill. 

mpacts to soils are addressed in th

3.19. Project is in preliminary design phase, with 3H:1V for stability and erosion control, where spamainly be constructed using on-site borrow matemix coal ash with soil on the site. 

Make sure all soil is 

The potential i
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.14 

Visual - 

Lighting 

One of the numerous foreseeable problems is the environmental impacts from light pollution that would impact area residences' lifestyles, livelihoods, and quality of life and scare away wildlife. The light pollution needs to be minimized. Other rail yards in and around Memphis are light polluters. IMF lighting should be directly lighting at the lowest possible elevation to avoids bleedover outside of the IMF. Would there be any lighting along the lead tracks (it's not necessary)? Would the lights used within the facility meet the dark sky requirements? The lights from a 24-hour facility would ruin the pleasure of the stellar night sky. Evaluation of Light Pollution from the proposed facility in your EA. 

Visual/lighting and potential impacts from the facconstruction are addressed in EA Sections 3.14, impacts off the IMF site from lighting will be avoidmitigated during project design. Light poles and within the container and trailer loading areas and the lead tracks. Lights within the yard area will bas opposed to the standard NSR 100-foot tall poyard area will be on standard 40-foot tall street pdirect light downward. The downward directing lillumination of less than 0.5 foot candle along the average light level within the facility ranges from Figure 3-20. NSR considered Dark Sky initiative light pollution and believes the facility design is cinitiatives even though none of the local communformal participants in Dark Sky. 

3.16 

Hazardous 

Materials 

that would undoubtedly be transported to/from this rail ng 

These containers only carry mainly consumer-oriented dry goods. Or are there going to be any hazardous materials off-loaded on the site? Is there going to be military hazardous waste coming through the IMF? The chemicals and associated hazardous materials yard would pose significant dangers and security threats. Concerned about hazardous materials/waste from on-site activities. The facility needs to have a hazardous materials crew that's trained periodically and is able to respond to hazardous material spills and conditions. 

Hazardous materials and potential impacts are aSections 3.16 and 3.18. Only a very small percecommodities moved through the IMF will be classThe spill prevention plan would address trainihazardous materials handling. As part of IMF op

trailers are transferred between the trucks and traSection 1. 

3.18 

Area 

Developer 

Is the Rail line continued into the Chickasaw Trails Industrial Park in Marshall County? Would a railroad track be built across Highway 72 at grade or would an overpass also be built there for traffic to and from Collierville, Tennessee? Would Mississippi have to pay for this? Mr. Adair is negotiating with people to buy other land in the area - future land sales to Norfolk Southern? Or related warehousing? Or related semi truck service stations? 

The cumulative impacts of the IMF are discussed 3.18, including some of the potential activities of anticipated growth of the Chickasaw Trails Indusareas. The Developer is considering an unrelaterail line to the Chickasaw Trails Industrial Park in project is separate from the IMF and is speculativgeneral development in the Chickasaw Trails Indconsidered in the cumulative impacts analysis. 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.18 

Economic 

Long-term 

Concerns

This facility is of no economic use to Mississippi where it is now located. I'm concerned about the traffic on the rail and highway that this is going to bring into the community. I'm concerned about pollution from the environmental standpoint and spin-off businesses. My biggest concern is the other activity that the IMF 

would be attracted into our community, i.e. low-end motels, fast food, etc. Finding oneself surrounded by an industrial area, rather than agriculture, would have a detrimental economic impact on 

the livelihood of those depending on area remaining agricultural. 

The cumulative impacts of the IMF are discussed 3.18. Fayette County has an urban growth plan planning and growth regulations. The Towns of and Collierville have defined urban growth boundboards for planning and growth regulations. Marzoning regulations. The property to be used for Bwithin the Rossville UGB and zoned industrial, F

3.18.2 

Traffic - 

Outside of 

Study Area 

Various concerns were expressed about the adequacy of roadways outside of the study area, including (a) Hwy 57/385 interchange, (b) widening of US 72, (c) construction of I-269, (d) a 4-lane N-S road from Us Hwy 72 to MS-302, (e) additional onramps from US Hwy 72 to SR-385, (f) widening and adding lanes to SR-385 (Bill Morris Parkway) from SR-57 to I-240, and (g) I-69 would have to be finished to connect with I-40 along with the extra on- and off-ramps for trucks. Recommend creating truck access points from both SR-57 and US Hwy 72. Various alternative traffic routing were expressed including: (a) stay off of SR-196, Knox Road and SR-57, (b) extend MS-302 (Goodman Rd.) to connect with SR-57, (c) connect US Hwy 72 and MS-302, and (d) widen SR-57 to 4-lanes from the IMF to SR-385. 

The indirect and cumulative impacts of the IMF aSection 3.18. Figure 3-23 shows the segment inThe last segment of SR-385 was in the TDOT Sewith an estimated completion date of September expected to directly increase traffic on SR-57, duTDOT is sponsoring a study of traffic impacts on network, including an assessment of other improalready scheduled. Figure 3-24 shows the propoNeither MDOT nor TDOT has released a construHwy 72 and I-269, respectively. 

3.18.2 

SR-57 

Overpass - 

Construction 

What is the cost estimate to build the SR-57 overpass for the railroad spur? What is the plan to close SR-57, when building that giant overpass? What is the timeframe that SR-57 would be closed or slow down traffic? Would [overpass] accommodate trailers and larger piece of equipment? What is estimated time of closure/re-route to construct overpass? Would the overpass design be 4-lanes, so won't have to redo the bridge when SR-57 expands in the future. 

The indirect impacts of the overpass construction EA Section 3.18 and 3.19. A temporary bypass wallow traffic to move along SR-57 during construcThe project is in the preliminary design phase. T

schedule and cost estimates for the SR-57 overpfinalized. 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.18 

Noise from 

Mainline 

Can Norfolk Southern do something to mitigate the noise made by the current through trains? For example: continuous welded rails, cushioned track beds, guarded crossings to avoid horn. 

The indirect and cumulative impacts of the IMF aSection 3.18. The NSR mainline already utilizes crossing warning devices are primarily the respohighway and local road departments. At-grade crequire train horn sounding per Federal regulatioare established by state or local authorities wishicommitting to installing warnings sufficient to proFRA and NSR may review requests from state ofor quiet zones at grade-crossings. 

3.18 Property 

Value 

F do to the value of our land? My concerns are: 

loss of property value, increased crime, bring in undesirable element, inability to sell my house for a decent fair market price, transformation of this quiet community into a distribution hub full of warehouses and support facilities for the thousands of trucks that would be traversing this area. Is NS responsible for plummeting property values and citizens not being able to sell homes and farms at any price? People are not interested in buying because of the potential noise and lights, which we would be facing. 

 on the experience from ot

What would the IM The indirect and cumulative impacts of the IMF a

Sections 3.18. Basedvalues of existing residential homes initially decrelong-term, property value increases. The current decreased the value of home across the US; thedetermine if the current resident’s inability to sell related to the proposed IMF or other factors. IMFattract development and jobs to the community. property values are not a natural outcome. Durinefforts will be made to minimize negative impacts owners and provide security around the IMF. 

3.18 

Stormwater - 

Airport 

Proposed stormwater retention ponds are non-compliant with the Federal standards and guidelines as set forth for General Aviation airports, with regards to both proximity to and wildlife attractants near airports. There are also several Federal Aviation Administration advisories regarding same, as well as established Agreements in place to which numerous government agencies are signatory. 

The indirect and cumulative impacts of the IMF aSection 3.18. In a letter dated 10/01/09, FAA staimpacted by the project. Both construction and pstormwater basins will be designed to avoid, minimpacts. The project will obtain and comply with permits. The detention basins would be designebasins. 

410 DOT, Federal Rail Administration, Use of Locomotive Horns at Highway-Rail Grade Crossings; Final Rule, 70 FR 21844, April 27, 2005, as amended 

17, 2006. 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

3.19.4 

F - 

I know you've got to construct water lines, sewer lines, and electricity. This infrastructure has to be constructed, so who is going to pay for this? What funds are the citizens going to be 

venues 

would Rossville/Piperton receive? 

unding 

Utilities 

paying on this? Tennessee residences are going to have to pay for the wear and tear on the local roads. How much does it cost to run a truck over the roads? Piperton would incur increased costs of providing water and sewer infrastructure to the facility, in an area annexed by Rossville. What tax and other re

The impacts to area utilities by the IMF constructoutlined in the EA Sections 3.15 and 3.19.4. The Industrial Road is providing (paying for) utilities to planned development. The project would pay for required for installing lead tracks. The potential idevelopments drawn to the area could increase tand Marshall Counties tax base and utility deman

4 

Other 

Most of the residents in this area don't know anything about the facility and they have certainly not been notified by Norfolk Southern. 

The public participation process is outlined in EA Coordination Plan on file with TDOT. In addition Information Meeting, local and governmental mediscuss the project and revise zoning. This envirwill also be publicly available and more public meforthcoming after the EA’s publication. 

4 

e meetings for? What is it we're discussing? How 

nions or let individuals discuss the issues in 

 of NSR. I object to his 

 he wanted Robin, from NSR to 

call me; this is a conflict of interest! 100s of people attended the 

ate for such a large 

proportion of NSR employees, be at and conducting the meeting. 

arriving early (before 4 pm) were welcome into th

d, guests were i

and talk to technical experts. No official 'this mee

Public Meeting 

What are thescan we influence this project, to what degree, in what areas? What can be influenced? TDOT presentation was not to inform and gather public opia "neutral" environment, since NSR's head lawyer opened meeting. This biased the meeting in favorcontinuing to stand facing landowners with a threatening stare. The questionnaire/comment sheet was misleading to general public in the way it was written. The summary sheet is useable. I want to go on record objecting that Tom Love has not returned my phone calls in two weeks. He saidmeeting, which concluded promptly at 7pm despite questions and 

concerns and people just arriving. Residence should had first option for questions. It was inappropri

The public involvement is addressed in the EA S22, 2009, the TDOT Public Informational Meeting accordance with TDOT Public Participation guidavariety of different methods to provide public inpusubmission of written comments following the me

issues with technical experts. During the formal questions were answered in the order they were formal presentation portion endeannouncement was made. TDOT representativeall members of the public left the room. Of the 75 in, 18 were representatives of NSR/TDOT/MDOTNSR to have technical experts available to answ

411 TDOT Public Involvement Plan, A Statewide Transportation Public Participation Guide, October 2007. 
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

Funding - 

Taxpayers 

What revenues would state governments be asked to contribute? And how much would the local taxpayers have to pay? If NSR plans to finance this “$129 million facility ... through a series of public-private partnerships”, what are those partnerships? What revenues would state governments be asked to contribute? TDOT should review the cost of this project to taxpayers versus the benefit. Taxpayer money should NOT be used to advance a corporation by giving an unfair advantage over its competitors. Is it possible that county taxes in both Marshall and Fayette county could increase? 

In addition to NSR funds, due to the employmentpublic benefits the project will bring, the construcconsideration for economic stimulus funding from government. The truckers using the IMF would plicense/fees like any other highway users. The pdevelopments drawn to the area could increase tin Fayette and Shelby Counties, Tennessee, and Mississippi and as noted in Section 3.6 of the draeconomic development in the region. The long-from State highways will reduce state highway mconstruction costs. 

ICCTA 

The railroad can do anything they want to do, is that right, from 

the laws that that were passed to give them the right-of-way back in the 1800's; is that right? It’s a done deal. They're going to build it right there. Isn't that right? 

If NSR constructs the IMF as described in this EAcompany is required to follow state and local builmaintenance, and permitting requirements, as weregulation and permitting requirements. Because 

Federal funding, NSR has also had to submit to treview process to determine a Build Alternative tand need for the project but also impacts the fewaddition, because of the Federal funding, NSR wcommitments for mitigation of any environmental here. For this project, NSR has complied with state and including those related to floodplains and zoningrecognition of the importance of rail transportatiocommerce, Congress has enacted legislation proregulated railroad operating in interstate commerapplicable local and state laws. See

 Interstate C

Termination Act of 1995 ("ICCTA"), 49 U.S.C.§ 1Railway Safety Act of 1970 ("FRSA"), 49 U.S.C.§ accordance with these and other similar federal llocal regulation of railroads is preempted in ordeinterstate commerce are not created. While statare subject to preemption, for this project local anthe extent applicable to rail would be observed.
4 PUBLIC INVOLVEMENT AND INTERAGENC

Memphis Regional Intermodal Facility 6/30/2010 

Table 4-3: Consolidated Public Comments and Response

Applicable 

EA Section / 

Category

Consolidation of Public Comments Responses 

NEPA 

Process 

Why is Norfolk Southern paying for the environmental study? Should an independent company hired by TDOT and MDOT make a study? Please conduct environmental studies that are NOT done by NSR. This is an obvious conflict of interest. 

NSR, through its consultant AMEC, is providing tassistance for information necessary for an EA. independently reviewed, edited, and compiled by and participating agencies, as well as the FRA. assist in preparation of technical documentation under NEPA and consistent with CEQ guidance. cooperating and participating agencies along with provide a fair environmental assessment of the pdeterminations made regarding the NEPA documare the purview of the lead agencies. 

Other 4) Past experience with TDOT assures that promises won't be kept, usually due to "lack of funding". Acknowledge comment. Other 

If all permits etc are approved, please provide a more detailed build/completion time line for the sites. RR, Highway upgrades, overpass, etc. 

NSR will obtain applicable Federal and State perwill to the extent required, therein, provide anticipschedule information. A list of potential permits nproject is identified in the EA Section 3.12.11. 

Other Is it possible that someone from Norfolk Southern can contacted us about any of this? NSR would be willing to contact and invite interes

subsequent public meeting to further discuss add

Other It would be great to be able to go to Rossville or Piperton, hop on the train and get into Memphis and back. NSR is a freight railroad. It does not conduct pas

Overpass - 

Design 

SR-57 Overpass, Good approach. It avoids blocking traffic with a rail crossing. It’s understandable to have the overpass over Highway 57 so the RR can be at ground level. I just hope it’s a 4-

lane vs. 2-lane for future growth. 

The grade separation concept is for the SR-57 ovlanes with 10-foot wide shoulders crossing over tautomotive/rail crossing delay 

Prioritization Why is this project taking precedence over other TDOT projects? Why is the IMF such a hurry up situation? 

The funding for this project is not part of TDOT's therefore, it is not taking precedence over other Tapproved, the Federal funding would be tied to thStimulus funding has specific timeframes that mu

Wind 

With all the paving that is proposed, much of the native flora and mature forests would be cut down. This could create more shear winds coming through. It would cause the locations to be barren, hot in summer, and drier all year. Would the facility cause the area become more arid in the future? 

There is no scientific evidence of any significant due to construction of an IMF facility. FRA does would become more arid due to the facility const
 APPENDIX A – AGENCY COMMENTS

Memphis Regional Intermodal Facility A-1 

6/30/2010 

Appendix A – Agency Comments 
Memphis Regional IMF A-2
Memphis Regional IMF A-3
Memphis Regional IMF A-4
Memphis Regional IMF A-5
Memphis Regional IMF A-6
Memphis Regional IMF A-7
Memphis Regional IMF A-8
Memphis Regional IMF A-9
Memphis Regional IMF A-10
Memphis Regional IMF A-11
STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION

Division of Natural Areas 

7th Floor L&C Annex 

401 Church Street 

Nashville, Tennessee 37243 

Phone 615/532-0431 Fax 615/532-0046

June 24, 2009 

Mary Motte Fikri 

AMEC Earth and Environmental, Inc. 

3800 Ezell Road, Suite 100 

Nashville, TN 37211 

Subject: Norfolk Southern Memphis Regional Intermodal Facility and Lead Track 

Fayette County, Tennessee, Rare Species Database Review, DNA 2009-023 

Dear Ms. Fikri: 

Thank you for your correspondence requesting an environmental review for the proposed Norfolk 

Southern Memphis Regional Intermodal Facility and Lead Track project in Fayette County, Tennessee. 

We have reviewed the state’s natural heritage database with regard to the project location, and we find 

that no rare species have been previously observed within one mile. 

Within four miles of the project, the following rare species have been observed: 

Type Scientific 

Name 

Common 

Name 

Global 

Rank 

St. 

Rank 

Fed. 

Prot. 

St. 

Prot. Habitat 

Flowering 

Plant Iris fulva Copper Iris G5 S2 ** T Bottomlands 

Mollusc Lampsilis 

siliquoidea Fatmucket G5 S2   

Slow-moving water with mud 

substrate; Wolf River (Mississippi 

River tributary); west Tennessee. 

May also occur at Reelfoot Lake. 

Mollusc Obovaria 

jacksoniana 

Southern 

Hickorynut G2 S1 **  ** 

Medium-sized gravel in water with 

low to moderate current; Wolf & 

Hatchie rivers; Mississippi River 

watershed; west Tennessee. 

We wish to emphasize that many areas of the state have been under-surveyed for rare species, especially 

portions of West Tennessee, and that the above list should not be used as a comprehensive guide for 

determining impacts to rare species. It is possible that additional rare species may exist in relatively 

Memphis Regional IMF A-12
Norfolk Southern Memphis Regional Intermodal Facility and Lead Track, Fayette County, TN 

Page 2, June 24, 2009 

undisturbed areas of the site including streams, wetlands, and bottomland forests. Based on aerial 

photography, the site appears to possess such areas with natural vegetation; accordingly, we suggest that 

the developer assess native habitats on the site and compare them with the requirements for rare species 

known to Fayette and Shelby Counties. As the state line lies within one mile of the site, we also 

recommend that you contact the Mississippi Natural Heritage program to determine whether there are 

rare species known to De Soto and Marshall Counties. If suitable habitat is found on the site or 

downstream of project activities, we ask that project plans incorporate protective measures for rare 

species. We also ask that you coordinate this project with the Tennessee Wildlife Resources Agency 

(Rob Todd, rob.todd@state.tn.us) to ensure that any legal requirements for protection of state-listed rare 

animals are properly addressed. 

Because the site drains into pristine reaches of the Wolf River and associated bottomland forests with 

known populations of rare species, we ask that the developer implement a robust system of both 

construction and permanent stormwater controls. For stabilization of disturbed areas, the Division of 

Natural Areas advocates the use of native trees, shrubs, and warm season grasses, where practicable. 

Care should be taken to prevent re-vegetation of disturbed areas with plants listed by the Tennessee 

Exotic Pest Plant Council as harmful exotic plants. 

Again, please keep in mind that not all areas of Tennessee have been surveyed and that a lack of records 

for any particular area is not a statement that rare species are absent from that area. For information 

regarding the protection status and ranks, please visit our website at http://state.tn.us/environment/na . 

Thank you for considering Tennessee’s rare species throughout the planning of this project. Should you 

have any questions, please do not hesitate to contact me at (615) 532-0440. 

Sincerely, 

Silas Mathes 

Heritage Data Manager 

Memphis Regional IMF A-13
Memphis Regional IMF A-14
Memphis Regional IMF A-15
Memphis Regional IMF A-16
Memphis Regional IMF A-17
Memphis Regional IMF A-18
Memphis Regional IMF A-19
Memphis Regional IMF A-20
Memphis Regional IMF A-21
Hagerty, Robin L

From: Straw, William [William.Straw@dhs.gov]

Sent: Tuesday, September 22, 2009 7:15 AM

To: Hagerty, Robin L

Cc: Tom Love

Subject: RE: Memphis Regional Intermodal Facility - Agency Letter (1)

Follow Up Flag: Follow up

Flag Status: Red

Page 1 of 2

12/13/2009

Dear Ms. Hagerty:

Good morning and thank you for the opportunity to comment on the Memphis Regional Intermodal Facility (IMF) 

near Rossville, in Fayette County, Tennessee.

FEMA’s authority and participation here is limited to informing and advising the lead Federal funding agency (or 

authorized designee), for them to make their project-specific regulatory compliance evaluation and determinations 

under Presidential Executive Order 11988 (EO 11988) for floodplain management.

EO 11988’s 8-step review process helps project decision makers to make more informed decisions about their 

project’s risks, options, costs, feasibilities, plans, designs, etc. EO 11988 requires documentation showing the 

project EO 11988 review was done, and the agency’s reasoning behind their project-specific EO 11988 

determinations. The project EO 11988 eight-step review and documentation can be integrated into the project 

NEPA review process and review document.

If the project may affect or be affected by a 100-year jurisdictional floodplain, then the lead Federal agency (or 

designee) would need to consult with all potentially affected communities’ Floodplain Administrators. For “critical 

facility” projects (e.g., police, fire, hazmat, public records, medical, nursing home, emergency shelter, water or 

wastewater treatment, etc.), that would be if the project may affect or be affected by the 500-year jurisdictional 

floodplain.

If applicable for the Memphis Regional IMF, that would require consultation with the Floodplain Administrators for 

Fayette County, and possibly for the City of Rossville, for their determinations. Both the County and the City 

participate in the National Flood Insurance Program (NFIP). Their Floodplain Administrators have floodplain 

management authority and responsibility for their jurisdictions. They may have different primary job titles. They 

may work in planning, zoning, development, public works, or another local government office. Search starting 

points:

Fayette County : http://www.fayettetn.us/

City of Rossville: http://www.fayettetn.us/Towns%20&%20Cities%202/Rossville%202.htm

Each NFIP-participating community (county, municipal, or tribal) has a floodplain management ordinance 

modeled on FEMA’s regulations at 44 CFR Part 60.3.

1) Such ordinances require anyone proposing “development” within a specific jurisdiction to get a 

permit from that jurisdiction before starting any project physical work.

2) Such ordinances also require notification of adjacent communities and the State NFIP Coordinator 

before altering a watercourse (if applicable).

3) Affected communities’ floodplain management regulations and related flood insurance policy holders’

premiums are both tied to mapped flood risks. When physical environment alterations affect flood 

risks, the corresponding Flood Insurance Rate Maps (FIRMs) must be revised as outlined in 44 CFR 

Part 65 to keep flood risk maps current.

Memphis Regional IMF A-22
If needed, the State NFIP Coordinator contact link is http://www.state.tn.us/ecd/CD_flood_insurance_prg.html.

Our office’s FIRM change contact is Mr. Mohammad Waliullah at 770-220-5493.

Please contact me again if I can help further.

Thank you again for the opportunity to comment on this project.

Best regards, +r

Wm R Straw, PhD

Regional Envir Plng/Hist Pres Ofcr

DHS/FEMA Region IV

770-220-5432

3Please consider costs/environment before printing this e-mail

From: Hagerty, Robin L [mailto:robin.hagerty@amec.com] 

Sent: Monday, September 21, 2009 7:49 PM 

To: Straw, William 

Cc: Tom Love 

Subject: FW: Memphis Regional Intermodal Facility - Agency Letter (1)

 

Regional Environmental Officer, Federal Emergency Management Agency,

 

The original letter (attached) did not allow you the required 30 days to respond to the ‘Invitation to be a 

Participating Agency for Memphis Regional Intermodal Facility (IMF) near Rossville, Fayette County, Tennessee’. 

We apologize for this confusion. 

As a Federal Agency, you must express in writing that you will not be participating before Oct 12. We assumed 

your agency would not be participating in the NEPA Process. To assist us in tracking participation, we would 

appreciate a response that you will be participating or will not be participating as soon as your reach a decision.

 

If you have any questions or concerns, please contact me or Tom Love, TDOT.

 

Thanks, Robin

Robin L. Hagerty, PE, CPESC®

Project Manager

AMEC Earth and Environmental

 

Tel (615) 333-0630

Fax (615) 781-0655

Mobile (615) 584-6031

Email: Robin.Hagerty@amec.com

 

The information contained in this e-mail is intended only for the individual or entity to whom it is 

addressed. 

Its contents (including any attachments) may contain confidential and/or privileged information. 

If you are not an intended recipient you must not use, disclose, disseminate, copy or print its contents. 

If you receive this e-mail in error, please notify the sender by reply e-mail and delete and destroy the 

message. 

Page 2 of 2

12/13/2009

Memphis Regional IMF A-23
Memphis Regional IMF A-24
STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

DIVISION OF WATER POLLUTION CONTROL 

7TH FLOOR, L&C ANNEX 

401 CHURCH STREET 

NASHVILLE, TENNESSEE 37243-1534 

October 12, 2009 

Mr. Tom Love 

Environmental Division 

Tennessee Department of Transportation 

Suite 900, James K. Polk Building 

505 Deadrick Street 

Nashville, Tennessee 37243-0334 

RE: Coordination Package and Invitation to be a Participating Agency for Memphis 

Regional Intermodal Faciligy (IMF) near Rossville, Fayette County, Tennessee 

Dear Mr. Love: 

We are in receipt of the above referenced material and are hereby advising you that the 

Tennessee Department of Environment and Conservation does intend to be a 

participating agency in the development of this project. At this time, we do not have 

specific comments on the Coordination Plan. 

Thank you for the opportunity to participate in the planning of this project. 

Sincerely, 

Daniel C. Eagar, Manager 

Natural Resources Section 

 

Memphis Regional IMF A-25
Memphis Regional IMF A-26
Memphis Regional IMF A-27
Memphis Regional IMF A-28
Memphis Regional IMF A-29
Memphis Regional IMF A-30
Memphis Regional IMF A-31
Memphis Regional IMF A-32
Memphis Regional IMF A-33
Memphis Regional IMF A-34
Memphis Regional IMF A-35
Fayette County Office of Planning & Development 

16265 Highway 64, Suite 4 Somerville, TN 38068 

Telephone: (901) 465-5250 Fax: (901) 465-5259 

 

Mr. Tom Love 

Transportation Manager I 

TDOT - Environmental Division 

Suite 900 – James K. Polk Building 

505 Deadrick Street 

Nashville, TN 37243-0334 

September 21, 2009 

Mr. Love, 

As temporary representative of the Fayette County Office of Planning and Development, I accept 

on behalf of John Pitner, Director TDOT’s invitation to participate in the Agency for Memphis 

Regional Intermodal Facility project. This office’s areas of concern are runoff and drainage, 

ground water contamination, traffic impact, blight and aesthetics as well as offensive noise, odor, 

smoke, dust, rubbish, heat, glare, or vibration discernable at the lot line. Thank you for the 

invitation to participate and please do not hesitate to contact me. 

Regards, 

Esther Sykes-Wood 

Assistant Planner 

OPD - Fayette County 

16265 Highway 64 Suite 4 

Somerville, TN 38068 

901-465-5250 

Memphis Regional IMF A-36
Memphis Regional IMF A-37
Memphis Regional IMF A-38
 APPENDIX B – SECTION 106 COORDINATION 

Memphis Regional Intermodal Facility B-1 

6/30/2010 

Appendix B – Section 106 Coordination


STATE OF TENNESSEE 

DEPARTMENT OF TRANSPORTATION 

ENVIRONMENTAL DIVISION 

SUITE 900 - JAMES K. POLK BUILDING 

505 DEADERICK STREET 

NASHVILLE, TENNESSEE 37243-0334 

September 22, 2009 

Mr. H. T. Holmes 

Mississippi Department of Archives and History 

P.O. Box 571 

Jackson, MS 39205-0571 

Subject: Section 106 Initial Coordination for Memphis Regional Intermodal Facility (IMF) near 

Rossville, Fayette County, Tennessee 

Dear Sir: 

The Tennessee Department of Transportation (TDOT), in cooperation with the Federal Highway 

Administration (FHWA), is initiating National Environmental Policy Act (NEPA) documentation and 

analysis for a proposed Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. The 

proposed IMF would be designed to handle containerized intermodal freight. The IMF would be 

located near the city of Rossville, approximately 1.5 miles south of State Route 57, 0.5 miles west of 

Knox Road, and 0.5 miles north of the Mississippi/Tennessee state line. A project data summary is 

attached showing the project location that is under study. 

The Advisory Council on Historic Preservation regulations stipulate that TDOT invite state historic 

preservation officers (SHPOs) to participate in the historic review process as a consulting party. TDOT 

would like to invite you, as the Mississippi historic preservation officer, to participate as a consulting 

party for the proposed project. 

If you choose to participate as a consulting party, you will receive copies of TDOT’s cultural resource 

reports and will be invited to attend project-related meetings between TDOT and the Tennessee State 

Historic Preservation Office (TN-SHPO), if any are held. As a consulting party, you should be prepared 

to attend any such meetings between TDOT and the TN- SHPO and provide a response to TDOT's reports 

in written form within 30 days upon receipt of the report. TDOT also wishes to seek your comments on 

the identification and evaluation of historic properties that the proposed project might impact. 

In coordination with the Tennessee Historical Commission, cultural resources investigations, which 

include archival research and a Phase I archaeological survey, are being initiated. The Area of 

Potential Effect (APE) for the archaeological survey is defined as the entire subject property 

boundary. 

No structures exist on the property except for a modern storage shed, which is less than 50 years 

old. A viewshed survey to assess visual impacts to historic architectural resources from the 

proposed Memphis Regional IMF is being initiated. The Tennessee Historical Commission has 

requested that the APE for the architectural viewshed survey be defined as a one-mile buffer around 

the proposed Memphis Regional IMF footprint. The viewshed survey APE extends into Marshall 

Memphis Regional IMF B-4
County, Mississippi. The tallest parts of the proposed project would be light fixtures 

(approximately 70 feet in height) and the crane used for loading and unloading containers 

(approximately 47 feet). 

If you would like to participate as a consulting party, please write to me at the above address. To 

facilitate our planning process, please respond within 30 days of receipt of this letter. Thank you for 

your assistance. 

If you have any questions or would like to discuss in more detail the project or our agency’s 

respective roles and responsibilities during the preparation of this National Environmental Policy Act 

(NEPA) documentation and analysis, please contact me at (615) 741-5364 or by e-mail 

(Tom.Love@tn.gov). 

Thank you for your cooperation and interest in this project. 

Sincerely, 

Tom Love 

Transportation Manager 1 

Enclosures: Project Summary 

Project Vicinity and Maps

Project Map Outlining APE 

 

Memphis Regional IMF B-5
Memphis Regional Intermodal Facility 

Project Data Summary Sheet Page 1 of 3 

Project Data Summary Sheet 

Project Location

Memphis Regional Intermodal Facility (IMF) in Fayette County near Rossville, 

Tennessee. 

General Project Description

Memphis Regional Intermodal Facility will be a rail terminal for transferring 

freight from one transportation mode to another, in this case between trains and trucks, 

without handling of the freight itself when changing modes. It is a large (approximately 

7,000 feet long by 2,400 feet wide) parking lot where the rail to truck and truck to rail 

modal containers are transferred. The IMF will assist in addressing projected future freight 

transportation needs, alleviating transportation bottlenecks and optimize shipping 

efficiencies between the Memphis region and the Northeast U.S. 

Project Purpose

The primary purpose of the proposed Memphis Regional IMF is to meet current 

and future demand for intermodal (rail/truck) transportation in the Memphis region. 

Norfolk Southern Railway Company (NSR) will build and own the facility. Its location 

relative to projected future growth in the Memphis area is a critical component to satisfy 

the project’s purpose. To meet the IMF’s operational requirements, the following main 

components needed are: 

 Tracks connecting the Memphis Regional IMF site to the NSR mainline 

(preferably without any at-grade crossings) 

 Six 4,000-foot long pad tracks 

 Support yard with 34,500 feet of track 

 Paved areas for the parking of up to 2,177 trailers and containers on chassis 

 Administration, maintenance, and operations buildings 

 Equipment maintenance pad and other related facilities 

Traffic

The roadway vehicle traffic will enter and exit the IMF through an independently 

developed access road (currently under construction) to U.S. Highway 72 in Mississippi. 

The 2009 average daily traffic (ADT) is approximately 11,200 vehicles per day (vpd). 

The 2015 ADT for the proposed site is expected to generate approximately 1946 vpd 

(1668 truck & 278 vehicle trips). 

Alternatives

Alternatives to be considered in the environmental document will include the NoBuild and the Build Alternative, avoidance, mitigation, and environmental enhancement 

alternatives for the Build site. The No-Build Alternative will mean that the proposed 

Memphis Regional IMF B-6
Memphis Regional Intermodal Facility 

Project Data Summary Sheet Page 2 of 3 

facility will not be constructed and existing NSR facilities in the area will continue to 

operate at current capacity. 

The Build Alternative is located approximately 1.5 miles south of State Route 

57 and 0.5 mile west of Knox Road near Rossville (Attachment 1). The proposed 

IMF would encompass approximately 570 acres, including an approximately 1.6-mile 

long, 200-foot wide right-of-way for lead tracks coming from the NSR mainline, 

which runs parallel to and north of State Route 57 (Attachment 2). The connection 

track corridor would include a grade separation at State Route 57 and a loop track at the 

south end of the facility for trains to reverse direction. Avoidance, mitigation, and 

environmental enhancement alternatives will be considered during the study and analysis 

phase of the NEPA process. 

Summary of Environmental Issues

As issues are identified through the NEPA process, additional study and 

assessment will be considered for the Project. 

Land Use

Most of the land within the project boundaries was previously disturbed 

and consists of both forested (mixed hardwood) and non-forested (hay fields) 

areas. The site consists of rolling hills and varies in elevation from approximately 

350-400 feet above mean sea level. Surrounding land areas may be categorized as 

forested, rural residential, and agricultural. 

Air Quality

Air quality effects will by analyzed for the affected study area, as well as 

emissions impacts of the transfer of freight from truck to rail. The results of these studies 

will be analyzed to determine the project impacts on the air quality of the area. 

Noise Evaluation

Noise studies will be conducted on the project. The results of these studies will 

be analyzed to determine the impact of the project on noise sensitive receptors. 

Hydrological Impacts

Construction of the project will likely impact streams in the area. The location 

and design of the project will consider impacts on these features and on the floodplains in 

the area and will be constructed in accordance with Executive Order 11988 and all local 

and federal regulations. In accordance with applicable law, mitigation of stream and 

wetland impacts will be including in the NEPA analysis and is anticipated as a condition 

of applicable permitting requirements. 

The project will be designed and constructed to minimize harm to the streams and 

environmental resources. During the construction of the project, strict adherence to all 

Memphis Regional IMF B-7
Memphis Regional Intermodal Facility 

Project Data Summary Sheet Page 3 of 3 

applicable provisions of TDOT’s Standard Specifications for Road and Bridge 

Construction and Best Management Practices will be followed. 

Ecological Impacts

Detailed terrestrial and aquatic studies will be conducted to determine the 

project’s impact on the ecological environment. Studies will be done to determine the 

presence of any endangered or threatened species or unique wildlife habitat that could be 

affected by the construction of the project or its operation. Attempts will be made first to 

avoid and minimize ecological impacts. If avoidance of adverse impacts is not possible, 

then mitigation measures will be developed to address impacts. 

Cultural Impacts

Historical and Archaeological studies will be done to determine if there are any 

sites or properties in the project impact area eligible for, or included in, the National 

Register of Historical Places. The studies will determine if the proposed project will 

affect any sites or properties of significance in the area. Avoidance and mitigation efforts 

will be evaluated as appropriate for impacts that may occur to these sites or properties. 

Farmland Impacts

Studies will be done to assess the project impacts on farmland or farmable land. 

A Farmland Impact Rating Form will be sent to the Department of Agriculture for their 

input. The results of these studies will be analyzed to determine any project impacts on 

farmlands. 

Socioeconomic Impacts

Analysis will be done to assess any project socioeconomic impacts including 

economic benefits to the region. 

Memphis Regional IMF B-8
DATE:

5/20/09

Rossville, TN

 Fayette County

Site Location Map

SOURCE:

AMEC Image Server

UGSG 7.5' Quad: 

Rossville, TN

PROJECTION: 

 TN SP FIPS 4100 (ft)

DATUM: NAD83

Ordered By: RH DATE: 8/6/09

Map By: LMB

Alabama Georgia

Tennessee

Kentucky

Mississippi

Arkansas

Missouri

Illinois

Virginia

South Carolina

North Carolina

Louisiana

West Virginia Indiana

Fayette Co.

AMEC Earth & Environmental

3800 Ezell Rd.

Nashville, TN 37211

Project 

Boundary

TENNESSEE

Memphis

Shelby

County

Fayette

County

Rossville

DeSoto

County Marshall

County

MISSISSIPPI

0 1 2 3 4 0.5

Miles

Memphis Regional IMF B-9
DATE:

5/20/09

Rossville, TN

 Fayette County

MRIMF Project Location

SOURCE:

AMEC Image Server

UGSG 7.5' Quad: 

Rossville, TN

PROJECTION: 

 TN SP FIPS 4100 (ft)

DATUM: NAD83

Ordered By: RH DATE: 8/5/09

Map By: LMB

Alabama Georgia

Tennessee

Missouri Kentucky

Mississippi

Arkansas

South Carolina

Illinois

North Carolina

Louisiana

Virginia

Fayette Co.

AMEC Earth & Environmental

3800 Ezell Rd.

Nashville, TN 37211

Project 

Boundary

US Hwy 72

Norfolk Southern Main Line

Proposed Independently Developed 

Access Road (not part of MRIMF development)

TENNESSEE

MISSISSIPPI

State Route 57

0 0.2 0.4 0.8 1.2

Miles

Memphis Regional IMF B-10
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Alabama-Quassarte Tribal Town 

101 East Broadway 

Wetumka, OK 74883 

Attn: Ms. Augustine Asbury, THPO 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Asbury: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Joyce Bear, Muscogee (Creek) Nation 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-11
TDOT PROJECT# 99108-1614-04 – Region 4 

MEMPHIS REGIONAL INTERMODAL FACILITY 

NORFOLK SOUTHERN RAILWAY COMPANY 

ROSSVILLE VICINITY, FAYTETTE COUNTY, TENNESSEE 

FAYETTE COUNTY

PROJECT LOCATION

MISSISSIPPI STATE LINE

Memphis Regional IMF B-12
TDOT PROJECT# 99108-1614-04 – Region 4 

Memphis Regional Intermodal Facility, Fayette County, Tennessee 

Page 2 

Memphis Regional Intermodal Facility, Fayette County, Tennessee 

Memphis Regional IMF B-13
TDOT PROJECT# 99108-1614-04 – Region 4 

Page 3 

Memphis Regional IMF B-14
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Tunica-Biloxi Indians of Louisiana, Inc. 

P.O. Box 1589 

Marksville, LA 71351 

Attn: Mr. Earl J. Barbry, Sr., Tribal Historic Preservation Officer 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Mr. Barbry: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Joyce Bear, Muscogee (Creek) Nation 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-15
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Muscogee (Creek) Nation 

Highway 75 and Loop 56 

Okmulgee, OK 74447 

Attn: Ms. Joyce Bear 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Bear: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-16
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Kialagee Tribal Town 

627 East Highway 9 

Wetumka, OK 74883 

Attn: Mekko Gary Bucktrot 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Mekko Gary Bucktrot: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Joyce Bear, Muscogee (Creek) Nation 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-17
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Mississippi Band of Choctaw Indians 

101 Industrial Road 

Choctaw, MS 39350 

Attn: Mr. Ken Carleton, Tribal Historic Preservation Officer 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Mr. Carleton: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Joyce Bear, Muscogee (Creek) Nation 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-18
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Choctaw Nation of Oklahoma 

P.O. Box 1210 

Durant, OK 74702 

Attn: Mr. Terry Cole, NAGPRA Representative 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Mr. Cole: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Joyce Bear, Muscogee (Creek) Nation

Memphis Regional IMF B-19
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Thlopthlocco Tribal Town 

Route 1 

Weleetka, OK 74464 

Attn: Mr. Charles Coleman, First Warrior, Historic Preservation Officer, and NAGPRA 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear First Warrior Charles Coleman: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Joyce Bear, Muscogee (Creek) Nation 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-20
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Eastern Shawnee Tribe of Oklahoma 

127 West Oneida 

Seneca, MO 64865-0350 

Attn: Ms. Robin Dushane, Cultural Preservation Director 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Dushane: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Joyce Bear, Muscogee (Creek) Nation 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-21
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Eastern Band of Cherokee Indians 

2877 Governor’s Island Road

Bryson City, NC 28713 

Attn: Mr. Tyler Howe 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Mr. Howe: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Joyce Bear, Muscogee (Creek) Nation 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-22
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Shawnee Tribe 

21 North Eight Tribes Trail 

Miami, OK 74354 

Attn: Ms. Kim Jumper/THPO 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Jumper: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Joyce Bear, Muscogee (Creek) Nation 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-23
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Jena Band of Choctaw Indians 

P.O. Box 14 

Jena, LA 71340-0014 

Attn: Ms. Lillie McCormick, Environmental Director 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms McMormick: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Joyce Bear, Muscogee (Creek) Nation 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-24
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

The Chickasaw Nation 

1001 No. Country Club 

Ada, OK 74820 

Attn: Ms. Gingy Nail, Tribal Historic Preservation Officer 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Nail: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Joyce Bear, Muscogee (Creek) Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-25
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

United Keetoowah Band of Cherokee Indians 

2450 S. Muscogee Avenue 

Tahlequah, OK 74465-0746 

Attn: Ms. Lisa Stopp 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Stopp: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Joyce Bear, Muscogee (Creek) Nation 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-26
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Poarch Band of Creek Indians 

5811 Jack Springs Road 

Atmore, AL 36502-5025 

Attn: Mr. Robert Thrower, Tribal Historic Preservation Officer 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Mr. Thrower: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Joyce Bear, Muscogee (Creek) Nation 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Carrie V. Wilson, Quapaw Tribe of Oklahoma 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-27
TDOT PROJECT# 99108-1614-04 – Region 4

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

THE ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334

(615) 741-5257 

Fax (615) 741-1098 

October 13, 2009 

Quapaw Tribe of Oklahoma 

223 E. Lafayette Street 

Fayetteville, AR 72701 

Attn: Ms. Carrie V. Wilson, Cultural Resources Director 

SUBJECT: Section 106 Initial Coordination for Proposed Memphis Regional Intermodal Facility, Rossville vicinity, 

Fayette County, Tennessee 

Dear Ms. Wilson: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway Administration is 

proposing to assist in the construction of the Memphis Regional Intermodal Facility (IMF) in Fayette County, Tennessee. 

Norfolk Southern Railway Company will build and own the $129 million facility, which will be located approximately 

1.5 miles south of SR-57 and 0.5-mile west of Knox Road, near Rossville. The Memphis IMF will be a rail terminal for 

transferring freight between trucks and trains. The facility will feature new rail tracks, including a 1.6-mile connecting line; 

a paved parking lot; access roads, administration, maintenance, and operations buildings; and an equipment maintenance 

pad. An access road to US 72 in Marshall County, Mississippi, will be constructed independently of this project. 

Approximately 570 acres of additional right-of-way in Fayette County, Tennessee, is needed (maps attached). 

The National Historic Preservation Act (NHPA) recognizes that federally funded undertakings, like the subject project, can 

affect historic properties to which your tribe attaches religious, cultural, and historic significance. In accordance with 

36 CFR 800 regulations implementing compliance with Section 106 of the NHPA, I would like to know if you have 

information you could share with me about tribal concerns in the project area and if you wish to be a consulting party on 

the project? Early awareness of your concerns can serve to protect things of value to the tribe. 

If you act as a consulting party you will receive cultural resource assessment reports and related documentation, be 

invited to attend project meetings with FHWA, TDOT, and the Tennessee State Historic Preservation Office (TN-SHPO), if 

any are held, and be asked to provide input throughout the process. If you choose to not act as a consulting party at this 

time, you can do so at a later date simply by notifying me. 

Please respond to me via letter, telephone (615-741-5257), fax (615-741-1098), or E-mail (Gerald.Kline@tn.gov). 

I respectfully request responses (email is preferred) to project reports and other materials within thirty (30) days of receipt 

if at all possible. Thank you for your assistance. 

Sincerely, 

Gerald Kline 

Transportation Specialist I 

Archaeology Program Manager

Enclosure 

cc Kim Jumper, Shawnee Tribe 

 Gingy Nail, Chickasaw Nation 

 Robin Dushane, Eastern Shawnee Tribe of Oklahoma 

 Mekko Gary Bucktrot, Kialegee Tribal Town 

 Augustine Asbury, Alabama-Quassarte Tribal Town 

 Tyler Howe, Eastern Band of Cherokee Indians 

 Charles Coleman, Thlopthlocco Tribal Town 

Lisa Stopp, United Keetoowah Band of Cherokee Indians 

Robert Thrower, Poarch Band of Creek Indians 

Lillie McCormick, Jena Band of Choctaw Indians 

Earl J. Barbry Sr., Tunica-Biloxi Indians of Louisiana 

Joyce Bear, Muscogee (Creek) Nation 

Ken Charlton, Mississippi Band of Choctaw Indians 

Terry Cole, Choctaw Nation of Oklahoma

Memphis Regional IMF B-28
-

STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334 

(615) 741-3655 

Fax (615) 741-1098 

September 29, 2009 

James C. Gaither, Sr., Mayor

City of Rossville

360 Morrison, P. O. Box 27

Rossville, TN 38066 

RE: Section 106 Early Consultation Notice for Memphis Regional Intermodal Facility near Rossville, 

Fayette County, Tennessee 

Dear Mr. Gaither: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway 

Administration is proposing to provide funding for the above referenced project. Its location is shown 

on the enclosed map. 

The Advisory Council on Historic Preservation regulations stipulate that TDOT invite local 

government representatives to participate in the historic review process as a consulting party. TDOT 

would like to invite you, as the local government official, to participate as a consulting party for the 

proposed project. 

If you choose to participate as a consulting party, you will receive copies of TDOT’s environmental 

reports and will be invited to attend project-related meetings between TDOT and the Tennessee 

State Historic Preservation Office (TN-SHPO), if any are held. As a consulting party, you should be 

prepared to attend any such meetings between TDOT and the TN-SHPO and provide a response to 

TDOT’s reports in written form within 30 days upon receipt of the report. TDOT also wishes to seek 

your comments on the identification and evaluation of historic properties that the proposed project 

might impact. 

If you would like to participate as a consulting party, please write to me at the above address. To 

facilitate our planning process, please respond within 30 days of receipt of this letter. Thank you for 

your assistance. 

 Sincerely, 

 Martha Carver 

 Historic Preservation Program Manager 

Enclosure 

Memphis Regional IMF B-29
STATE OF TENNESSEE

DEPARTMENT OF TRANSPORTATION

ENVIRONMENTAL DIVISION

SUITE 900, JAMES K. POLK BUILDING 

505 DEADERICK STREET

NASHVILLE, TENNESSEE 37243-0334 

(615) 741-3655 

Fax (615) 741-1098 

September 8, 2009 

Mr. Skip Taylor 

Fayette County Mayor 

13095 N. Main, P.O. Box 218 

Somerville, TN 38068 

RE: Section 106 Early Consultation Notice for Memphis Regional Intermodal Facility near Rossville, 

Fayette County, Tennessee 

Dear Mr. Taylor: 

The Tennessee Department of Transportation (TDOT) in cooperation with the Federal Highway 

Administration is proposing to provide funding for the above referenced project. Its location is shown 

on the enclosed map. 

The 2001 Advisory Council on Historic Preservation regulations stipulate that TDOT invite local 

government representatives to participate in the historic review process as a consulting party. TDOT 

would like to invite you, as the local government official, to participate as a consulting party for the 

proposed project. 

If you choose to participate as a consulting party, you will receive copies of TDOT’s environmental 

reports and will be invited to attend project-related meetings between TDOT and the Tennessee 

State Historic Preservation Office (TN-SHPO), if any are held. As a consulting party, you should be 

prepared to attend any such meetings between TDOT and the TN-SHPO and provide a response to 

TDOT’s reports in written form within 30 days upon receipt of the report. TDOT also wishes to seek 

your comments on the identification and evaluation of historic properties that the proposed project 

might impact. 

If you would like to participate as a consulting party, please write to me at the above address. To 

facilitate our planning process, please respond within 30 days of receipt of this letter. Thank you for 

your assistance. 

 Sincerely, 

 Martha Carver 

 Historic Preservation Program Manager 

Enclosure 

Memphis Regional IMF B-30